Ticket to Work Evaluation (February 2004)

APPENDIX C

Defining the Four Adequacy of Incentives Groups

To conduct an AOI analysis, we must be able to identify beneficiaries who would fall into the four legislatively defined groups and thus could find it difficult to obtain services in the performance-based TTW environment. While the Ticket Act does not define the AOI groups in a way that allows them to be identified straightforwardly using SSA administrative data, the evaluation design report (Stapleton and Livermore 2002) provides a method for creating reasonable approximations of the first two groups and for using detailed survey data and analysis to identify the last two groups. These methods are described below.

A. IDENTIFYING INDIVIDUALS WITH A NEED FOR ONGOING SUPPORT SERVICES (AOI GROUP 1)

The evaluation design specifies a way to use SSA administrative data about beneficiaries’ primary impairments to identify individuals likely to need ongoing supports. The approach considers impairments that are likely to result in:

• A frequent need for personal assistance or coaching (e.g., cognitive disabilities, autism, other developmental disorders, traumatic brain injury, other severe cognitive disorders, quadriplegia)
• A tendency to be able to work only episodically (e.g., psychiatric disorders)
• Possible disruptions of a person’s work activity (e.g., uncontrolled seizure disorders)
• A gradual decrease in functional capacity, possibly making long-term employment retention more difficult (e.g., multiple sclerosis, degenerative arthritis)

The relevant sections from SSA’s listings of impairments, along with the associated SSA impairment codes, are detailed in Table C.1. The rough approximation of the AOI group based on impairments will be refined later using administrative data about other beneficiary characteristics such as educational and employment history. For example, longitudinal SSI earnings data or even historical FICA tax reports could possibly be used to assist in the identification of these individuals. Relevant SSA records should become available to the evaluation in December 2003, reflecting the normal lag time for acquiring these data.¹

Table C.1: SSA Listing of Impairments Codes for Individuals with a Need for Ongoing Support Services

B. IDENTIFYING INDIVIDUALS WITH A NEED FOR HIGH-COST ACCOMMODATIONS (AOI GROUP 2)

High-cost accommodations include supports such as assistive technologies, workplace modifications, job coaching, personal assistance services, and interpreter or reader services. The evaluation design proposes to identify individuals in this subcategory in the same way beneficiaries with ongoing support needs are identified, by making a priori assumptions of subgroup membership based on primary impairment code. These impairment codes are included in Table C.2 and attempt to include conditions that result in the inability to use two or more limbs, severe neurological impairments (e.g., spinal cord injuries), deafness and severe auditory impairments, and blindness and severe vision impairments.

Table C.2: SSA Listing of Impairments Codes for Individuals with a Need for High-Cost Accommodations

C. IDENTIFYING INDIVIDUALS WHO EARN A SUBMINIMUM WAGE

The evaluation design assumes that most beneficiaries in this category will be working in sheltered workshops, but others might be working in competitive employment situations through a subminimum wage certificate. We anticipate that identifying these individuals will be very challenging, because SSA administrative data do not contain wage data. For SSI recipients, monthly earnings are available, but hours worked are not. Reports of annual earnings subject to FICA taxes are routinely reported, but again do not contain wage information and are only available after a 14-month time lag. The evaluation design proposes to develop a prediction equation for subminimum wages for beneficiaries with earnings, using detailed wage and hour data from the Survey of Income and Program Participation that have been matched to SSA’s administrative data. The resulting prediction model could subsequently be applied to the administrative data to predict the hourly wage rates for beneficiaries with earnings and begin to identify individuals who have a high probability of earning subminimum wages. Another option is to identify the similar group that has monthly earnings that fall well below what would be earned by a full-time worker who was paid the federal minimum wage.

D. IDENTIFYING INDIVIDUALS WHO WORK AND RECEIVE PARTIAL CASH BENEFITS

In any given month, many SSI recipients may be working and earning wages, even above the level designating substantial gainful activity, yet not sufficient to reduce their cash benefit to zero.² Because a Ticket holder must be in zero cash benefit status to generate an outcome payment for an EN, Congress was concerned that these individuals might have a particularly difficult time locating an EN willing to accept their Ticket and provide them the services necessary to increase their earnings and ultimately reduce their cash benefit to zero. Individuals who receive partial cash benefits can be identified through SSA administrative data. These individuals may actually be earning wages that might, in some situations, reduce their benefit to zero, yet continue to receive a benefit payment through the use of various work incentives (e.g. Plan for Achieving Self Support, subsidies, Student Earned Income Exclusion, etc.).

In the next evaluation report, we will identify SSI beneficiaries who receive partial benefits because of work by focusing on their reported earnings during the prior 12 months. In particular, we will analyze those who have (1) some earnings in at least one month, and (2) earnings above the individual’s minimum disregard in one or more months. While the concept of partial cash benefits does not apply to DI-only beneficiaries on a monthly basis, on a longer term basis it does apply to those DI beneficiaries that have intermittent employment experiences that cause them to cycle in and out of payments during their Extended Period of Eligibility. Specifically, we will focus on DI beneficiaries that (1) receive FICA-covered earnings in a given year and (2) experience an interruption in benefit payments during at least one month of the year. We will also identify DI beneficiaries who "work and receive full cash benefits," defined as beneficiaries who intermittently use trial work period months, but do not enter the Extended Period of Eligibility. The data required to implement this definition are expected to be available in time for the evaluation’s next report in spring 2004 (see Chapter VIII).

Notes:

¹ The evaluation team will not have direct access to FICA tax reports because of data confidentiality rules. However, SSA staff will assist the evaluation by using that information to help develop more refined definitions of the AOI groups, and those definitions will be available. Return to text.

² DI beneficiaries receive either the full cash benefit for which they are eligible or no payment at all. Return to text.