Promoting the Use of PASS

	Promoting the Use of PASS Plans in Montana by Ellen Condon In two Model Transition Demonstration projects in Montana, Social Security work incentives are incorporated into transition planning for students with significant disabilities in need of ongoing supports to maintain employment. These projects are funded by the U.S. Department of Education. Work incentives can be a valuable resource in transition planning for several reasons. Work incentives are one avenue for generating financial resources to fund career development and employment for eligible students while they are in school and as they transition to adulthood. In a PASS plan, income or resources can be sheltered and used to fund employment preparation at the time the PASS is approved, or saved to purchase future employment supports, services, or equipment. The PASS plan is a viable alternative funding source for students in need of ongoing supports who may be graduating to agency waiting lists for these services. Work incentives, such as PASS plans, are a source of funds that promote choice and control for families and students who utilize them. PASS plans are flexible in what they fund as long as they support employment. For example, PASS plans have been used to purchase vehicles, job development services, vocational evaluations (or community-based alternatives such as Vocational Profiles), transportation, start-up equipment for small businesses, and other items or services needed to obtain employment, and advance employment. In the case of someone who utilizes supported employment services to maintain those services, PASS plans must lead to improvement in income or reduction in job coaching. With work incentives, there are fewer restrictions on whom families and individuals can contract with to provide services than with state or federal disability funds. This results in increased consumer choice and control. One difficulty in transition planning is that school services are provided to students only until graduation and many adult services do not begin until after the student exits from high school. The hand-off from one system to the other is not always seamless and the individual is often left with a substantial gap in funding and services in the course of transition. Additional cause for concern is that unlike school Special Education programs, Adult Services are not entitlement programs. Adult Services are based upon eligibility and availability. In some states students who graduate from Special Education programs and are eligible for Development Disabilities services may wait years for an opening that may not even provide the services they need. Social Security work incentives can be used for eligible students both while they are in school and after they graduate. They can bridge the gap of services available between youth and adult life, while allowing the individuals and their families to choose their own supports, services, equipment, and providers that best fit their needs. Are Students Really Eligible for PASS Plans? In January of 2001, the amount of wages students were allowed to earn before it impacted their SSI checks increased substantially. As of January 1, 2003, students could earn up to $1,340 per month, or a total of $5,410 per year before their wages decreased their SSI payments. This incentive is referred to as the Student Earned Income Exclusion (SEIE). While this is a positive step toward allowing students to work, earn wages, and continue to receive the full SSI check, it decreases the likelihood that students will qualify for PASS plans. To be eligible for a PASS, an individual must have income or resources that reduce their SSI check. Students who are still enrolled in school will probably not work enough hours to put them over the $5,410 per year Student Earned Income Exclusion allowance. In those instances where a student has unearned income which reduces their monthly SSI check, he or she is eligible for a PASS plan while still in school. The sources of unearned income that made students in the Rural Institute Project eligible for PASS plans included: Adoption Subsidies, Survivor’s benefits, and SSDI through a retired or disabled parent’s SSA account. Students as young as age 14 have had PASS plans approved, since they had a resource or income that reduced their monthly SSI check. In the case of younger students, the PASS funds can be set aside for future support needs or utilized to purchase services, supports, or items necessary to achieve a current vocational goal. As soon as a young adult graduates from school the SEIE no longer applies. Only the first $85 per month of earnings is excluded. After the first $85 per month gross earnings (for those receiving only SSI) their monthly SSI check is reduced 50 cents on a dollar earned, thereby making them eligible for a PASS plan. In the Montana pilot schools, the goal was to have students with significant disabilities graduate into paid jobs working at least 20 hours per week. In one Montana school all three project participants were working at the time of graduation and were also on waiting lists for adult employment services from the State Developmental Disabilities agency. All three required some form of ongoing supports to maintain their employment. PASS plans were written for each student sheltering their wages to pay for their needed supports so that they could continue to work after graduation. Early transition planning was essential for all three of these students. Each student’s Individual Education Plan (IEP) team recognized the ongoing support needs of the students and documented this need in the student’s Needed Transition Services. They also made provisions to link the students and their families prior to graduation to appropriate agencies or to support people that could fund and provide services after graduation. PASS plans were written, submitted to the PASS Cadre, and approved in advance of the student’s graduation, contingent upon post-graduation earnings. Since the exact amount of money that students would earn monthly was not known, the PASS was written for the amount that their SSI checks would decrease (the sum of gross wages less $85, divided by two). Creating a System to Promote the Use of SSA Work Incentives To promote the use of SSA work incentives in transition to employment planning, the task is approached on multiple levels through various phases of implementation. It begins by demonstrating the effectiveness of Social Security work incentives for students. Next, strategies are identified to promote the use of these resources in schools and to encourage schools to incorporate these strategies into their transition planning processes. This includes developing informational products and venues to educate consumers and providers about these incentives. Phase three involves the training of agency and school staff, as well as parents, in accessing and using these incentives. Phase four of implementation involves developing community capacity to provide benefits counseling, and to provide the service of writing PASS plans or accessing other work incentives. Developing Community Capacity to Provide Benefits Counseling and Promote the Use of Work Incentives Building community capacity begins by asking “Which agency representatives would most benefit from having students graduate with a PASS account or funds in place to cover a portion of their own job supports?” For example, a case manager for Developmental Disabilities services will probably be happier to come to a transition meeting to offer information about PASS plans than to come to the meeting to inform a student and the family that there is a five-year waiting list for the services the student needs to secure and maintain a job. A Vocational Rehabilitation Counselor may be more motivated to approve a request for funds to purchase equipment which will enable a student to more efficiently perform his or her job, knowing that the student has a source of funding to pay for ongoing supports for maintaining that job (i.e., a PASS plan or an IRWE). Adult agencies are also encouraged to assist in identifying students eligible for work incentives and to support families and students through the process of securing funds to access a PASS plan or Benefits Analysis. Benefits Analysis is a review of the person’s current financial situation to provide information about eligibility for work incentives and the impact of income on their benefits. Promoting the use of PASS plans and Benefit Analysis is one potential new role for them to play at transition meetings. Discussions to have in your community which could help students access PASS plans: Who in your community can provide information about Social Security and PASS plans to schools, families, and students? Are your local schools sharing information about SSA and work incentives on a regular basis at IEP meetings? Could Case managers, Independent Living Centers or Employment agency representatives share this information at Transition Planning Meetings? Who will write PASS plans for eligible students? Will your local Vocational Rehabilitation Office or Workforce Agencies fund PASS Plans for Students? Our goal is for work incentives and Benefits Analysis to be viable options on the menu of services which students can access during transition planning. In order for people with disabilities to take advantage of these options, they must be aware of them and agencies and vendors need to offer them as services. In Montana, as information is disseminated to promote work incentives, providers who might be interested in offering or funding these services are also identified. Montana State Vocational Rehabilitation pays their enrolled agencies $460 per PASS plan developed for students in their “exit year” of high school. In the Missoula area, only two vendors currently provide a PASS plan development service. Still to be explored as funding options for developing PASS plans are Workforce Investment funds, SSA Tickets to Work, and Developmental Disabilities funds. Countering the Myth that SSA Work Incentives Are Not Part of Transition Planning for Students. As waiting lists for services grow, students and their families need support to access all available funds to secure employment as a post school outcome. Students in remote rural areas may need to generate additional resources to create an optimum vocational experience while in school and to access or create community employment upon graduation. Although by law, schools are mandated to provide an education which prepares students for their desired post-school outcomes, schools in small towns may simply not be equipped to provide top-quality job coaching, transportation, and job development services. Students with PASS plans could use their SSA funds to augment school services or to begin their own entrepreneurial venture. Self-employment is an increasingly attractive and viable source of income for people with disabilities especially in rural areas (Griffin, C. & Hammis, D., 2002). As noted above, waiting lists for adult services are growing. Graduating students with ongoing support needs are being placed on waiting lists for employment services. As they sit at home waiting for services they could lose valuable skills learned in high school, may become ingrained in a way of life without work, and could be more expensive to place into jobs. Students who have a job and a PASS plan upon graduation can fund their own supports and set aside monies to pay for future job development or on-the-job support services. Conclusion While barriers to utilizing SSA work incentives persist, they are nonetheless a viable source of funding to support transition planning and post-school supports for graduating young adults receiving SSI benefits or who are eligible for SSI. In fact, our work indicates that they might even be viewed as a preferred method of funding because of their flexibility and the ability for consumers to choose providers and have control over services. More demonstration needs to be done illustrating how PASS plans and other work incentives can be built into transition planning. Supports and programs need to be developed to make the process of analyzing each person’s SSA benefits and the impact that going to work will have on these benefits, less overwhelming to families, schools, and agencies. Benefits Analysis and the provision of work incentives need to be viewed as an essential service for people with disabilities, as prevalent and accessible as supported employment or supported living.

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