In comments to the Social Security Administration (SSA) on improving employment outcomes for youth with disabilities, PWDF said that the SSA can play a role in assisting the transition of youths to adulthood, given the requirement of vocational rehabilitation agencies to serve transition-age individuals by ceasing age 18 redeterminations and instead doing them at age 22. We also said that the SSA might better support other agencies’ youth transition-related activities by making wages for all internships, apprenticeships, and sheltered employment non-countable as substantial gainful activity (SGA) so these TAY can learn job skills without fear of first losing benefits.

In response to a question as to whether SSA can improve aspects of its publications, mailings, and online information to better support successful transitions to adulthood of youths receiving SSI, PWDF commented that SSA can achieve this by deleting bureaucratic notices and by using plain clear language not exceeding the 7th grade level. We said that SSA can improve its existing work incentive policies, such as the Student Earned Income Exclusion (SEIE) and Impairment-Related Work Expenses (IRWEs), to better support and increase SSI youth engagement in work, by taking into account the pathology of each specific disability which is, inter alia, required by the term “impairment-related.”

In response to the SSA’s question about whether it should expand the Ticket to Work (Ticket) program to include children or create a separate program for children with a similar mission (i.e., reimbursing service providers whose services result in increased employment and reduced need on cash benefits), we said they should not, because the Ticket program has not been successful since it was mandated by Congress and sign into law by Pres. Clinton in 1999.

PWDF submitted these comments last month in response to the SSA’s Request for Information (RFI) on Strategies to Improve Adult Outcomes for Youth Receiving Supplemental Security Income (SSI), Docket No. SSA-2017-0049, as published in the Federal Register (83 FR 411 (Jan. 3, 2018)).

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