So You Submitted Your PASS Plan

	So, You Submitted Your PASS Plan. What Happens to It Now? An Interview with Roxanna Hunt from the Denver Region PASS Cadre; conducted by Ellen Condon What is the Review Process that Cadre Staff Go Through upon Receipt of a PASS Plan? Procedures state that the individual should submit their PASS plan to their local Social Security office who then mails the original plan to the person’s PASS Cadre office, although many plans are being submitted directly to the Cadre. On the day the PASS plan arrives we send the applicant a letter acknowledging we received the plan and requesting any additional information that we need to make a decision. We check the additional items that we need from the list on page 2 of the letter (See Appendix D for a sample PASS Cadre letter). We ask that the information be sent within 30 days. We also send the applicant a Household Expenses Worksheet. We ask them to complete this illustrating their portion of the household expenses to ensure they can support themselves even when they are putting some of their money into a PASS account each month. (See Appendix D for a sample worksheet.) We also enter each individual’s information into a database. We have a computer system set up for anyone who has ever applied for or has had a PASS plan. It is called the Cadre Information System (CIS). We track the type of plan, the vocational goal and whether or not the plan was successful. We check the system to make sure that if the person has had a previous plan, it was for a different vocational goal. If they did not finish their original plan and are applying for another PASS plan, we ask if they have a good reason for abandoning the plan. If there is a good reason, we will probably give them another chance. How the review process works: We review the PASS plan for completeness. Was it signed by the individual and their representative payee if they have one? Even if the person is not their own guardian they must sign the PASS plan. The guardian is not required to sign but the representative payee must always sign. We look at the vocational goal. This goal is the desired end employment. If someone is attending school, education is not the vocational goal, rather the vocational goal is the job they will have after graduation that will make them-self sufficient. If the person does not know their vocational goal they can write the PASS plan for the purpose of obtaining an assessment to determine it. We review Part I, Section D of the PASS plan. We expect that through work you will reduce your SSI payments if you receive only SSI or SSI and SSDI concurrently. If you receive only SSDI we expect your goal to be losing your SSDI eventually by earning over the Substantial Gainful Activity rate. ($800 per month in 2003). We ask if someone else helped you write the PASS plan. If you check the “yes” box and provide their phone number and address, we interpret this as your release form for us to contact them. We look at the medical and vocational information to determine if the goal is feasible. If Vocational Rehabilitation (VR) provides any supporting documentation that this goal is feasible or if they are serving you, we deem the goal feasible immediately. If you are working with VR, we will ask to contact them to obtain a copy of your Individual Plan of Employment. In Part III, we look for the date you want your PASS plan to begin and end. You can write it retroactively for the time you have been eligible for SSI and the PASS plan. We will want to make sure that the length of the plan gives you enough time to pay off large ticket items or to achieve your goal. If your plan timeline ends but you need more time to complete the plan we will consider an extension. We ask you to outline what steps you will take to achieve your goal. Include at what point you will purchase big ticket items, what month you intend to increase your hours and wages, when you will begin a job, or what classes you will take. Buying vehicles: In Part IV, we want you to explain why you need to buy a car (if that is what your plan is for). Reasons such as: no public transportation available or need an adapted van due to disability are adequate. You won’t be turned down if you don’t have a driver’s license, but if your plan says that you will drive the vehicle we will want to see that you have started the process of obtaining a license. In Part IV of the PASS application, you are asked to list: what you will purchase, how much it costs, who will provide the service, and how it will assist you to meet your vocational goal. It helps to get several price estimates on expensive items (cars, computers, business equipment, etc...) and include written estimates in your initial application. The more information you provide here the stronger your plan appears. Example: I will purchase a Dell 2000 computer for $1,357.00. I must be able to do school work on a computer and use the computer for my vocational goal. I am unable to use the computer lab at school. Also indicate if this will be a one time payment, if you will save up using your PASS account, or if you will get a loan that you will pay toward monthly using your PASS account. In Part IV Section D, you need to report your current living expenses. You will complete the “Household Expenses Worksheet” to show the amount you need to live on. (Remember to divide the entire monthly living expenses by the number of people living in the house). We will look at the worksheet to determine if you are able to live on the FBR of $552 a month if all other income goes into the PASS account. In Part V, you are asked about funding for your vocational goal. If you will use items you have already owned such as a computer or car, if you have saved any other money, or have resources which may make you ineligible the PASS reviewer will inform you that you could set them aside in the PASS plan making you eligible for SSI. List any other income that will assist you to support yourself, such as, self-employment income, wages, SSDI, a spouses income, etc. Indicate the other agencies who are also providing support for your vocational goal: employment networks, VR, Workforce, the school, etc. Indicate what assistance they are providing. If the PASS cadre has not received the information we requested on the acknowledgment letter within three weeks, we will resend the request via certified mail. Usually within 30 days from the date which the Cadre staff received all the requested information a decision about funding the PASS plan will be made. What Factors Help Speed Up the Approval? Supply written cost estimates for big ticket items and attach these to the PASS application. Complete all the information on the PASS form (what will you buy, from whom, and why it is needed). Have signatures of the applicant and their representative payee (guardian signature is not needed). Include a cover letter explaining your overall situation and plan to achieve self-support. Include letters from your employers expressing their commitment to increase your hours or their opinion about your employability increasing due to a purchase through the PASS plan. Include letters from anyone who can support the feasibility of your goal. Include a completed Household Expenses Worksheet. Include your contact information in case Cadre staff have questions; phone number, time of day they can reach you for more information, a fax number. Include information or loan paperwork and estimates on equipment. Faxed copies are OK. If you are unsure of your vocational goal, write the PASS plan for Assessment. Include all information that supports the feasibility of your vocational goal, for example: • School IEP that explains your vocational goal or skills; •Assessment information such as a Vocational Profile or other functional vocational evaluations; •Paperwork from VR or Workforce which supports your vocational goal; and •Relevant medical information. Include contact information for people who could share information that will support the feasibility of your goal or vouch for your abilities. (Include a signed release of information, SSA form 3288 to enable the PASS Cadre staff to gather additional information.) If your goal is self-employment, include a business plan, and involve small business resources such as, the Small Business Association and SCORE. (See the PASS Manual by the Denver PASS Cadre located on the Transition website www.ruralinstitute.umt.edu/transition) You can write a PASS plan to pay for a business plan to be developed or for a business feasibility study to be performed. If VR has approved your business plan the PASS Cadre will assume that it is feasible. If you are asking for the PASS plan to pay for school, include information about the school’s program, curriculum, graduation requirements and class schedule. Include information about grants or scholarships for which you have applied. What factors most commonly slow down the approval? Incomplete PASS plan. Needed signatures not included. How long does it take to have a PASS approved? If the application is complete, I can approve the PASS plan the day I receive it. It typically takes 30 days if it takes me awhile to accumulate all the supporting information, and up to 60 days if I am waiting for VR to determine eligibility or if a person’s goal is self-employment. Once a PASS is in place, is there a monitoring process that is universal to all PASS Cadres? Yes. There should be no longer than 12 months between reviews of a PASS recipient’s progress and compliance. I do progress checks within the first 2 months to ensure that the PASS account was set up correctly, the correct amount of money is being saved, and retroactive monies were issued correctly. The amount of time between reviews is up to the individual PASS Cadre member. Typically it is every 6 months if self-employment is the goal. Also the PASS Cadre will review a plan more often if the person is saving for future expenses or the person is planning to purchase big items, to ensure that the money is still in the account. Once a plan is approved, what does an individual or representative payee need to collect for accounting records or documentation to show they spent the money according to their plan? 1) PASS bank account statements-having direct deposit of the funds into the PASS account and automatic payments for cars or other loans makes the money easier to track but this is not mandated. 2) If the PASS plan is for education: semester schedules, proof of attendance (e.g. school’s attendance records), tuition receipts, report cards (students need to maintain a 2.0 GPA, and be enrolled in the program at least ½ time), transcripts showing classes taken, a list of the classes needed to graduate, and the expected graduation date. 3) All receipts of monies paid out for items or services. 4) Original receipts of purchases. 5) A statement or report from the job coach or tutor about an individuals progress and increasing self-sufficiency. 6) Reports from experts/service providers involved in the PASS milestones, and 7) VR will be asked to report on current progress and to list items or services which they have purchased to limit overlapping of funds. ** In the initial letter indicating that the PASS plan was approved, the accounting should have been explained along with the amount approved for each expenditure or purchase. After the Cadre staff has reviewed the account, a letter will be sent to indicate whether or not the individual is found to be in compliance. Under what circumstances should an individual contact you to provide new information about their plan? Individuals are required to report their monthly gross wages to their local SSA office by the 10th of the next month and provide the original pay stubs. If the person is earning more than they originally planned to earn and they want to shelter more money in their PASS plan they should call their PASS Cadre staff. If self-employed, report income at the end of the year via tax returns. If they move, change addresses, phone number or representative payee they should call or send the PASS Cadre staff that information. If there is any change in the income they are setting aside. If a medical issue or another reason causes them to stop pursuing their vocational goal. (The PASS plan can be suspended for a year if the person is temporarily not pursuing their goal). If they change vendors of services, or if they want to make any changes in what they had written in the plan. Under what circumstances would someone with a PASS plan end up in an SSI overpayment situation? As long as they are using the money as it was allocated in the plan they will not end up in an overpayment situation and owe money back to SSA. However, if they misuse the money, quit the plan and do not inform the PASS Cadre and keep getting SSI to which they are not entitled, or if money that is supposed to be in the PASS account is not there, they could end up owing money to SSA. If an individual never achieves the intended vocational goal this is not considered an overpayment as long as they followed the plan and used the PASS money for approved expenses. At the end of the plan if someone hasn’t spent all of the money in their PASS account where does it go? If an individual needs more time to complete their plan they can request an extension. If they need the money left in their account it can be rolled over to the new PASS plan. They need to make sure they will have enough expenses on which to spend the left over money and the additional sheltered amount. If they have expenses that the money can pay for which were not listed in the original plan they can ask for an amendment which will allow them to use the unspent money for another work expense. If they are done with the PASS plan or choose not to pursue it any longer, They will write a check to the local SSA office for the amount in the PASS account. Their Social Security Number will need to be on the check. They should keep a copy of the check for their records. If they find any additional receipts after they have closed their account, they can submit the receipts after the fact as long as it is within a year of the ending of the PASS plan. Are you seeing many PASS plans being submitted for students? No not really! But we welcome PASS plans for students. When would someone ask to extend a PASS plan? Amend a PASS plan? At any time during their PASS plan they can request an amendment or an extension. It can be done automatically by Cadre staff if the review has been completed and they have not completed the PASS plan. Their PASS Cadre staff will send out the paperwork to offer an extension before the PASS plan ends. If they began saving money and it is getting close to the $2000 limit they can have while receiving SSI, they can choose to amend their PASS plan and shelter this additional lump sum in their PASS account. However, the money must be used toward the vocational goal. There is a one page form for extensions or amendments or a they can retype the changed information on their original PASS application. Highlight the changes and type EXTENSION or AMENDMENT at the top of the form, or just type the changed information on a new blank form, indicating extension or amendment on the top. The easiest path is to call the Cadre staff and explain the situation so the Cadre staff can talk them through the process. If the change does not effect their SSI payment the Cadre staff may just authorize the change in their case notes and not require paperwork from them.

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