It Doesn’t Take a Rocket Scientist:
To Understand & Use Social Security Work Incentives
General PASS Plan Requirements
A Plan for Achieving Self Support (PASS) allows a person with
a disability to set aside countable income and/or resources for
a specific period of time to realize a work goal. Any person
who receives SSI benefits, or receives SSDI and could qualify
for SSI, can have a plan. There is no limit to the number of
successful PASS plans a person may have in a lifetime.
Basic Requirements
The plan must:
• Result in a decreased reliance on the Social Security system
• Be designed specifically for the person
• Be in writing (can be written by
anyone)
• Have a specific work goal that the
person is capable of performing. SSA PASS Specialists will presume
a PASS to be viable if Vocational Rehabilitation or a certified
rehabilitation professional says the goal is feasible.
• Have a specific time frame for reaching
the goal
• Show what money and other resources
received will be used to reach the goal
• Show how the money and resources will
be used
• Show how the money set aside will be kept separately from
other funds
• Be approved by the Social Security Administration
• Be
reviewed periodically to assure compliance
Likely Candidates for a PASS
» Resources in Excess of Allowable Limits
Individuals who do not have earned or unearned income and
who have not qualified for SSI in the past due to resources over the
SSI resource limit (generally defined as over $2000 in non-excluded
resources) may use a PASS to set aside some or all of the excess resources
to achieve a vocational goal and, as a result, qualify financially for
SSI.
» Unearned Income Only
Individuals with unearned income only (SSDI, railroad retirement
checks, veterans benefits, parental subsidies/gifts,
etc.), can write a PASS to exclude the income (using all or part of
the income to pay
for PASS expenses) and thereby establish SSI/Medicaid
financial eligibility.
» Earned Income Only
Individuals with disabilities who have earned income only
can set aside the countable portion of their earnings in a PASS to become
financially eligible for SSI/Medicaid.
» Both Earned and Unearned Income
Individuals who have both earned and unearned income can
set aside their countable wages, or unearned income, or both in a PASS
and thereby establish SSI/Medicaid financial eligibility.
» Earned Income and Receiving SSI/Medicaid
Individuals who have earned income and who are receiving
SSI checks can set their countable earnings aside in a PASS, which will
result in full SSI checks while they work toward their PASS goal.
» Earned Income (in the future) and Receiving SSI/Medicaid
Individuals who have SSI only, but who will begin working
in the near future, can write a PASS to set aside countable new wages
starting with the first month of employment. The SSI check will only
be reduced by the amount of countable income not set aside in the PASS.
» In School or Training
Potential PASS candidates having income/resources, including
individuals with disabilities in school or training programs, currently
receiving services from rehabilitation agencies, or interested in rehabilitation
and becoming self-supporting.
Who May Help Set Up a Plan?
Anyone (e.g., vocational counselors, social workers, case managers,
employment specialists, or employers) may help a person
with the plan. Vocational Rehabilitation (VR) Counselors
are especially
good candidates since their involvement in the applicant's
PASS indicates feasibility, oversight, and the blending
of public resources, which SSA encourages. SSA expects
that by using a
PASS, a person will decrease his/her reliance on benefits
or cease to be eligible at all. VR can also pay for a PASS
writer to write a PASS for someone.
PASS Approval Requirements
1. Feasible Occupational Goal
SSA now requires that an occupational goal be certified
as feasible for the person. A Vocational Rehabilitation
counselor or a person with CRC credentials can certify
feasibility. The goal is the job the person wants or
wants to maintain.
The goal can also be self-employment. SSA will look
at the
goal, the age of the person, any prior work history,
education and training, and type of disability. The
PASS must also indicate
any current earnings and estimated earnings after the
PASS has been completed. SSA will expect that "SSDI-only"
recipients will have earnings over the SGA level ($940/month
in
2008) at the end of their PASS.
2. Interval Steps/Milestones
The PASS should include specific milestones that document
a person's progress toward achieving his/her stated
PASS goal. These should be concrete statements (e.g., begins
school/job coaching, hired for job, etc.) that
show the steps
to goal achievement.
3. Definable Timetable
Specific time frames for meeting the milestones must be
established within the PASS. Provide schedules for meeting
the milestones and the vocational goal, indicating the month
and year each step is expected to begin and end.
4. Income/Resources to Be Set Aside
Plans must state the sources and amount of income or
resources to be set aside (earnings, benefits, savings accounts,
etc.). The sources and amounts must be adequate to achieve
the goals, but cannot be excessive. Separate accounts for
PASS monies (checking accounts) provide excellent verification
of PASS savings and expenditures.
5. Expenditures
The PASS must state how the money set aside will be
spent to achieve the occupational goal. A list must be included of
planned expenditures, with an explanation of their connection to the
occupational goal. Expenses must be reasonable to be approved. Cost
estimates for goods and services should indicate how the cost was calculated.
6. Organization
The PASS must be in writing, but there is no mandatory
format as long as all questions are answered that appear
on the SSA PASS form. Forms are available at your local
SSA office,
on the SSA website at http//www.ssa.gov/online/ssa-545.pdf,
or the Rural Institute website at
http://ruralinstitute.umt.edu.
7. Deferred Expenses
Not all expenses may be allowed at the beginning of the
PASS. In some cases, approval of certain goods and services
may be contingent on the successful completion of milestones
that justify the expense.
Examples of Possible PASS Expenditures
• Equipment, supplies, start-up capital, and inventory required to establish a business
• Any cost associated with an educational or occupational training
program, including tutoring, counseling, vocational evaluation
and work experience, etc.
• Attendant care/personal assistance
• Child care
• Equipment or tools, either specific to the individual's
condition or designed for general use
• Uniforms, specialized clothing (including dress business
clothing), safety equipment
• Least costly alternatives for transportation including:
- Public Transportation and common carriers
- Hire of private or commercial carriers
- Purchase of a private vehicle
• Dues and publications for academic or professional purposes
• Modifications to buildings or vehicles to accommodate a person's
disability
• Licenses, certifications, and permits necessary for employment
or self-employment
The PASS Work Incentive will fund any goods/services that will enable
a person to become more self-sufficient. PASS funds are frequently
portioned out over the duration of the PASS. Paying for items
must be prioritized
as to their relative importance in the person's employment
plan. For example, a new vehicle may be a high priority at the outset
of planning, but due to the expense of other items that are
critical
to the success
of the plan, a less expensive model may be preferable.
In many ways, PASS plan preparation is another avenue for Vocational
Rehabilitation counselors and participants to define employment and
career goals in the light of resources.
Funding Supported Employment Services Through PASS Plans
Supported Employment (SE) services may be funded using a PASS. Only
in a Supported Employment PASS can the goal be to "maintain"
a job. "Increased self-suppor"” in most PASS plans implies
an increase in earnings, but in Supported Employment PASS plans,
"increased self-support" may include reduced reliance on
job coaching or other services or an increase in the hours
someone is able to work.
The plan should specify (estimate) the anticipated declining
level of supports required over time (fading schedule) or the
anticipated schedule
of increased hours worked.
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