National Alliance on Mental Illness
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(800) 950-NAMI; firstname.lastname@example.org
I strongly believe that SSI, SSDI and the Ticket program require major reform. Therefore, I urge that the Social Security Administration (SSA), the Social Security Advisory Board (SSAB), the Ticket to Work and Work Incentives Improvement Advisory Panel (the Panel) promptly consider and implement these recommendations.
I. BENEFICIARIES’ NEEDS MUST BE PRIMARY: The Ticket fails to address the realities and priorities of the vast majority of disabled beneficiaries. Addressing these will require substantially restructuring the program, and must become the explicit, highest priority of efforts to improve the Ticket, not saving Social Security Trust Fund dollars.
Many beneficiaries want to work, but few share the Ticket’s goal of working their way off cash (and possibly medical and other needed) benefits. Yet, Employment Networks (ENs) typically get paid only when the ticket-holder’s earnings make them ineligible to receive their disability check. Hence, their financial interests are often pitted against those they ostensibly serve.
II. FIX FUNDAMENTALS FIRST: While much effort and resources are going into fixing the flaws of the Ticket, more fundamental problems with the overall SSDI and SSI programs - including other "work incentives" – which adversely impact far more beneficiaries than the Ticket will possibly benefit, remain largely unaddressed.
For example, eliminating SSDI’s cash cliff and raising SSI’s unrealistically low asset limit and income exclusions (the former has only been increased $500 while the latter have never been raised over SSI’s 30 year history) would do more to help a greater number of beneficiaries work to their fullest potential than tinkering with the Ticket’s technicalities or how it is marketed. Structural disincentives and other impediments to work must be redressed before the great majority of beneficiaries should or will risk losing needed benefits as a result of working.
III. ENSURE FULL DISCLOSURE ABOUT THE TICKET: SSA must ensure that information provided about the Ticket be complete and accurate. The literature describing the Ticket is incomplete and therefore misleading. It states that this program is to help people work, but fails to indicate that it really is only for those wanting and able to work their way completely off cash benefits, thus of no benefit for the vast majority of beneficiaries.
IV. INVOLVE BENEFIARIES IN THE TICKET’S DESIGN, IMPLEMENTATION AND EVALUATION. The Ticket’s flaws, as previously noted, stem, in part, from the lack of sufficient input from beneficiaries in its design and implementation. Two suggestions to partially remedy this are:
A. Establish a beneficiaries advisory group to provide systematic input about the Ticket to SSA and the Ticket Panel on the full array of work incentive programs.
B. The Panel is considering a study on the overall financial impact and implications when a beneficiary works their way off of disability. This is a good - albeit belated - idea, however beneficiaries must play a significant role in conducting the study if it is to fully capture work’s impact on financial status and needed benefits and services.
V. ACCOMMODATE REALITIES OF PSYCHIATRIC DISABILITIES: Establish a task force to recommend how individuals with psychiatric disabilities can be better served by SSDI, SSI and the Ticket. Additionally, the Panel is planning for a study to examine the unique work-related issues facing these individuals - who must, along with others knowledgeable in this area, be importantly involved in it’s conduct.
"Psychiatric Disabilities," is the largest and fastest growing category of disabled beneficiaries, yet these programs are ill-suited for the realities of these individuals, as well as others with fluctuating levels of impairment.
VI. GUARANTEED HEALTH INSURANCE IS ESSENTIAL: If the Ticket is to have any chance of succeeding, access to needed health care must NOT be contingent on income, assets or any other status which might be affected by working. The Ticket Panel members seem to realize this truth; they should publicly assert it.
SDI & SSI advocate
July 23, 2004