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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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