PASS Plans as a Vehicle
for Transition to Employment
Case 1:
Ann
Step 1: Determine if the student is eligible.
When Ann was 16 years old and a sophomore in high school, her benefits
were reviewed to determine whether or not she was eligible for a PASS
plan. She was already receiving SSI, the first criteria in qualifying
for a PASS plan, but because she was receiving the full amount she was
ineligible. Since she had no resource or income reducing her SSI check
there was no financial benefit to writing a plan for her at that time.
However, since she was eligible for SSI we knew that we should remain
aware of any future income or resources which would reduce her check thereby
making her eligible for a PASS plan.
A few months later, Ann’s Individual Education Plan (IEP) team
learned that her biological father had passed away and she would begin
receiving Survivor’s benefits of $305.00 a month through his retirement
account. Her SSI check would now be reduced by $285.00 a month (SSA excludes
the first $20.00 of unearned income).
Her team chose to write a PASS plan which would “shelter”
the unearned income. Her monthly SSI check would then remain at the Federal
Benefit Rate (FBR) of $552.00 month. She would shelter her $285.00 a month
in a PASS account to support the pursuit of her vocational goal.
Impact of Unearned Income on SSI
$305.00 Unearned Income -20.00 General Income
Exclusion
$285.00 Amount Counted by SSI
$552.00 SSI at the 2003 FBR - 285.00
$267.00 Amount of SSI Ann Would Receive Without a PASS Plan
Total Income = $267.00 +305.00
$572.00
Total Income with a PASS Plan
$ 20.00 General Income Exclusion +552.00 SSI at the 2003 FBR
$572.00*
* Plus $285.00 in a PASS Account to Use to Pay Towards Vocational Goals.
Events that could make an ineligible student eligible
for a PASS plan:
Parent dies, becomes disabled, or retires;
Student graduates and is working, earning over $85/month;
Parent income of a student under the age of 18 increases, which causes
the student’s SSI check to decrease.
Step 2: Identify a vocational goal.
IDEA legislation states that at age 14 (or earlier if appropriate), schools
must assist students who are receiving Special Education services to identify
their “desired post-school outcomes.” IDEA also states that
the Transition Service Needs, including the student’s curriculum
or “course of study” should be leading them towards or preparing
them to achieve these post-school goals.
Ann’s IEP team began with the assumption that Ann could work in
the community in a position in which she could contribute, if the job
was customized to meet her needs. They spent time gathering information
about who Ann was; what her preferences and interests were in regards
to employment; what her support needs were; what job tasks she could perform;
and what her particular contributions might be to an employer. They learned
that Ann had an exceptional memory for schedules and details and she very
readily offered solutions to difficulties in juggling transportation or
staffing schedules in the classroom, but her IEP team did not know how
this would work into specific job tasks or an actual position.
From what was discovered about Ann, the team established that Ann’s
long term vocational goal was to obtain a position as a Logistics Coordinator.
However, Ann had limited work experience, so the IEP team decided that
it would be beneficial for Ann to have some additional experiences which
would provide her and her team with more information about her ideal conditions
of employment.
Step 3: Determine the length of the plan.
PASS plans can be written for any reasonable length of time that is needed
to achieve the goal. In Ann’s case, she had been eligible for a
PASS plan for some time prior to the plan being written and approved.
Since she had been receiving SSI this entire time, the PASS plan was written
starting 6 months retroactively. This generated a sum of back payment
money which was used to pay for expenses which were more than the $285.00
a month she would set aside. This particular plan ended 2 months following
graduation. It was assumed that the PASS plan would be amended if her
goal changed or if she needed to purchase something different. If Ann
was employed a new plan would be written to reflect the procured job.
Step 4: Draft the steps of the plan.
In this section of the PASS plan, the team mapped out the actions or activities
that needed to occur to support Ann to achieve her work goal of becoming
a Logistics Coordinator. (See below for a complete list of steps). The
Transition Projects staff chose to support her in some additional work
experiences the summer before her exit year of high school which provided
Ann and her team with more information about her abilities and support
needs. In order for her to participate in employment during the summer,
Ann needed transportation, someone to develop an employment site, and
someone to provide instruction and support on the job
Steps of Ann’s Plan
Accomplishments prior to PASS submission
Beginning
Date End Date
Began transition planning including employment 3/99
Attended PASS plan training in Polson, MT. 10/00
Attended Vocational Profile training in Polson, MT.
2/01
Began unpaid work experience
9/00 ongoing
Contact Vocational Rehabilitation to apply for services 4/01
Submit PASS plan
4/01
Secure employment exploration site #1
6/01 7/01
Identify driver and summer job coach 6/01
7/01
Complete job exploration site #1 7/01
8/01
Secure employment exploration site #2 7/01
8/01
Complete job exploration site #2 8/01
9/01
Complete written Voc. Eval. (Voc. Profile) 9/01
10/01
Steps to reach goal after PASS plan approval
Identify job developer 11/01
Begin job development 11/01
12/01
Begin work with assistance of job coaching 1/02
Continue working part time while in school 1/02
6/02
Graduate from high school 6/02
Secure ongoing supports through Developmental 5/02
9/02
Disabilities services
Increase hours at employment upon graduation 6/02
Ongoing
Step 5: Develop a budget to support the Plan.
Ann’s budget illustrates how the projected amount sheltered in her
plan would be spent in order for her to achieve her vocational goal. The
costs need to be justified and information provided about how each expense
helped Ann to achieve her goal. (The more information provided in the
PASS plan to the PASS Cadre, the stronger the plan. See below for an example
of a budget.)
Budget to Support the PASS Plan
1. Item/service/training: Transportation - Cost: $900
for 3 months = $2,700
($15 a day up to $300 a month; for 3 months (summer only) as the school
will transport during the school year).
Vendor: To be determined.
How will this help you reach your goal?I need transportation into town to get to my job
exploration sites because I live in a rural area that is 20 miles north
of Polson.
How did you determine the cost?Going
rate in the community determined from asking
around town.
Why wouldn’t something less expensive meet
your needs?Since I don’t drive I
will need to hire someone to drive me into town and back using my wheelchair
accessible van. This is the least expensive option.
2. Item/service/training: future job coach supports
Cost: $6,910.00
Vendor: To be determined, paid at a rate of $45.00 a hour.
How will this help you reach your goal?I will need support to initially learn and perform
my job. After I learn the job, I will need some personal care at work
daily and follow-along support to assist me in maintaining my performance
and advancing in my job. Since the services and supports I will need are
not an entitlement after I graduate, I would like to shelter this money
for these future support needs. For the period of this PASS I will request
funding from Vocational Rehabilitation to pay for job development and
initial job coaching.
How did you determine the cost?Going rate
in the community as determined from Vocational Rehabilitation payment
standards.
Why wouldn't something less expensive meet your
needs?Above amounts are all the lowest
costs available.
Step 6: Demonstrate how the PASS account funds
will be kept separate from other monies.
Ann opened a checking account that was to be used for PASS funds only.
She provided SSA with the account number, bank name, address and phone
number. (The SSI recipient or the representative payee will be required
to account to SSA for all monies expended from this account. It is helpful
to keep all back statements, carbon copied check registers, and receipts
for payment or bills for services rendered).
Step 7: Document that the pursuit of this vocational goal is a collaborative
venture between funding sources.
Social Security, like other agencies, wants to see that they are not the
sole funding source for transition activities or employment. Ann’s
plan included information about what the school provided for supports
and services and estimated the amount it cost. Also included was what
Vocational Rehabilitation (VR) agreed to pay for, as well as, other person
or agency, who was supporting Ann to become employed. (A letter from the
Rehabilitation Counselor on their letter head would be a good supporting
document to include in a PASS Plan.) If VR is not yet providing financial
support due to the age of the student, reference this fact in the cover
letter which is submitted to SSA with the completed PASS plan.
Will any other person or organization (e.g.,
VR, school grants, Job Partnership Training Assistance (JTPA) pay for
or reimburse you for any part of the expenses listed in Box 7 or provide
any other items or services you will need? If "YES", provide
details as follows:
Who will pay Item/Service
Amount
When
will item/ service be purchased?
Polson Schools Vocational
Eval. $750
Summer
2001
VR Job
Development up to $1000
Summer 2001
VR Job
Coaching up to $2000 Summer
2001
Rural Institute
Technical Assist. $3000
Senior
school year
Comprehensive Dev.
Services
Van
to use $300/month
Item
is being used currently
Step 8: Include Supporting Documentation
Build a strong case so the PASS plan will be approved. It is not always
clear to Social Security that the stated work goal is feasible for the
individual or that the steps identified will lead him/her to achieving
the goal. Give SSA an overview of the plan in the initial cover letter.
Leaving gaps in the information provided will most likely lead to delays
in having the PASS plan approved. Include any other documentation that
would build the argument that the vocational goal is appropriate and feasible.
Ann’s team included her Vocational Profile and Employment Planning
Meeting minutes which summarized the ideal characteristics of her future
employment. (For people with a greater impact of disability, a non-traditional
vocational evaluation would help build the argument that a vocational
goal is more feasible than the traditional standardized vocational evaluations).
Include documentation that supports the prices budgeted to pay vendors
or to pay for equipment are reasonable. Include several bids in writing
if proposing to purchase an expensive item through the PASS plan. Instead
of waiting for SSA to request information about household expenses after
submitting the PASS plan, include a completed Household Expense Worksheet.
Basically SSA wants to make sure that the applicant will have adequate
money available to pay for food and living expenses after sheltering money
in the PASS plan.
Remember to have the applicant and their representative payee sign the
completed PASS plan. Make a copy of the document and all supporting documentation.
File the copies with other important SSA documents. Send the completed
PASS simultaneously to the regional PASS Cadre and to the individual’s
local SSA office.
Addendum:
Ann:
Ann moved away from Polson and is not employed at this time. The unspent
money in her PASS account was returned to SSA since she was no longer
following her plan. She can request that her previous plan or a new plan
begin when her circumstances change. She maintains ownership of her van.