Question 9

Question: I am helping someone write a PASS plan. Should I write it in the first person (as if the person I’m assisting is writing it)? That is, should I write, “My work goal is…” or “John Smith’s work goal is…”?

Answer: Write it in the first person because the individual you are assisting is actually the one submitting the PASS.

Question: Can the PASS be typed or must it be handwritten?

Answer: It can be typed right on a printed-out PASS form which is available at http://www.ssa.gov/online/ss a-545.pdf, and then photocopied before sending; or
it can be typed on an electronic form, and then saved on your computer, as well as printed out; or you can get a PASS form from the local SSA office, or download it from the website above, and fill it out by hand. The advantage to typing the PASS and saving it on your computer is that it will save you time in the future if you need to request an amendment or an extension, or if the PASS Cadre requests changes to your original plan.

Question: What’s the best way to decide the time frame of the PASS plan, such as when it should end?

Answer: Ideally you want the PASS end date to coincide with the person achieving her or his vocational goal. For example, if the vocational goal is to become a Veterinary Technician and the individual is using a PASS to pay for school, the end date would coincide with completing the degree program.

As a general rule, though, figuring out the end date of a PASS is just about the last thing the writer should do. First, list all the items the PASS will buy and their costs. Then total the cost of all the goods/services. Divide this total by the monthly amount the person has available to put into the PASS. The result of that division gives you the number of months the PASS needs to run so that everything is paid for. That is the fewest number of months the PASS will need to run - it might run longer if the goal takes longer to finish. In the alternative, the goal might be finished before the expenses are all paid, and that's okay. A PASS isn't over until both the goal is accomplished and all the expenses are paid.

Question: What are the benefits of using a PASS plan for supported employment versus using an Impairment Related Work Expense (IRWE)?

Answer: PASS plans are often more financially beneficial for an SSI recipient because twice as much money can be sheltered through a PASS as can be reimbursed through an IRWE; a PASS allows the person to save beyond one month at a time; and allowable expenses are not limited to those related to the person’s disability.

IRWEs are simpler to claim and are not time-limited like PASS plans. An IRWE allows an SSI recipient to be reimbursed for monthly out-of-pocket expenses which are impairment-related and necessary to work.

There is not “hard and fast policy” on when to use a PASS and when to use an IRWE. Rather, this is one more instance of decisions that need to be made on a person-by-person basis, based on each individual's particular circumstances.

Question: In PASS plan training, we were told Social Security would like to see $830/month or more as expected earnings after the plan is completed (so the individual’s Social Security benefits will be reduced). What if the recipient is only able to work a maximum of four hours per day?

Answer: At the end of a PASS, Social Security wants to see what they term a "decreased reliance on benefits." For SSI, that simply means that at the end of a PASS, a person needs to be receiving less SSI per month than they were receiving before the PASS. The reduction in SSI usually occurs because the person has increased their hours of work by using the PASS, or has increased the amount of their hourly wage or self-employment earnings.

The $830 amount applies to people who have only SSDI at the beginning of their PASS. When someone has only SSDI, the only way they can reduce their "reliance on benefits" is to consistently earn over Substantial Gainful Activity (SGA) ($830/mo in 2005) so that SSA cuts (or believes it will be able to cut) them off their SSDI benefits altogether. People CAN earn $830/month or more and still actually keep their SSDI benefits if they also have Impairment Related Work Expenses, or if someone else is paying for services and/or supports that help the person keep their job. The “someone else” might be an employer who pays to widen aisles and make a bathroom accessible, or pays the person a typical wage even though the person works more slowly or performs fewer duties, or it might be a school or employment agency that pays for job coaches to help the person, or anything similar.

Question: Could a PASS plan be used to cover health-related therapies (such as biofeedback, physical therapy, natural medications, etc.) that might help an individual stay healthy and miss less work?

Answer: While the therapies could certainly be included in the PASS if you show how they will assist the person to meet his or her vocational goal, these are very appropriate expenses for Montana Vocational Rehabilitation to cover because they can help individuals both keep their jobs and improve their health (restoration). If VR declined to pay for the therapies, it would be useful to see the policy supporting the service denial.

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