Options Plus Issues Public Comment on SSA Notice

WASHINGTON, Oct. 26 -- Options Plus Inc., Hollywood, Florida, has issued a public comment on the Social Security Administration notice entitled "Request for Information: Potential Disability Insurance and Supplemental Security Income Demonstrations". The comment was posted on Oct. 21, 2021:

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The Ticket to Work Program (TTW) has been an under-performing program due to several factors. Bear in mind that in traditional vocational guidance, as provided by Vocational Rehabilitation, only about one-third of the disabled clients seeking employment guidance and or support, actually succeed. The private Employment Network (EN) companies providing those services are expected to operate without up front financial resources.

There are several changes to the program that would make private Vocational guidance services significantly more likely to succeed. The current rules are biased to not pay for services rendered by limiting means of communication with the administering TTW agency. Limited acceptable documentation for proof of employment earnings is one impediment. Documentation of self-employment can result in only a partial compensation for a year of proven income that would be counted as only one month of SGA income, while the Social Security Administration uses quarterly or annual earnings to determine SGA earnings.

The ENs are not assured of fair compensation. there is a lack of communication and advocacy by the TTW administration with Social security Administration to ensure a fair accounting of TWP and SGA earnings. The disabled worker can easily face an over-payment situation that can end SGA employment for them.

The EN company finds their earned fees "raked back" and can never recoup those fees when the over-payment is corrected. Lastly, there is no program to consider that it is difficult for a person with disabilities to go from no work to full-time employment. A program that allows for a partial reduction of benefit payment against above TWL earnings after a TWP would be of benefit.

In short, ensure that the EN Companies have the resources to provide the service and support needed by a person with disabilities by ensuring fair compensation for services rendered.

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The notice can be viewed at: https://www.regulations.gov/document/SSA-2021-0025-0001

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