People With Disabilities Foundation (PWDF) submitted public comments in April 2016 to the Social Security Administration (SSA) with recommendations for potential revisions to Ticket To Work program rules. The Ticket To Work program seeks to assist Social Security disability beneficiaries find and maintain employment that leads to increased independence and productivity. These comments were submitted in response to the SSA’s Advance Notice of Proposed Rulemaking, Docket No. SSA-2015-0025.

PWDF provided commentary in three general fields. In addition, PWDF provided responses to specific areas of interest to the SSA. Areas of commentary included recommendations for accommodations for people with episodic disorders, encouraging Employment Networks (ENs) to develop individualized plans based on a beneficiary’s impairments, and not counting earnings as Substantial Gainful Activity (SGA) while a ticket is active. Areas of interest covered in the comments included:

• Specific Employment Support Models
• Effective Ways to Present Information to Improve Participation and Outcomes
• Supports to Manage Finances and Benefits
• Fostering Program Success with ENs
• EN Payment Structures
• Fostering a Robust Market of Employment Support Services

PWDF repeatedly encouraged SSA to focus on developing individualized plans for program participants. PWDF believes that ENs overly generalize. We recommend that beneficiaries be divided into categories that are tailored to their individual disabilities. For example, a beneficiary who has low mental functioning because of autism and/or intellectual disability has different needs from beneficiaries with other impairments, e.g., physical. The more the SSA does towards this end, the better the results that can be expected.

If you would like to read PWDF’s full commentary for revising the Ticket to Work Program, you can find our comments here.