Supplemental Security Income:
SSA Could Strengthen Its Efforts to Encourage Employment for Transition-Age Youth
GAO-17-485: Published: May 17, 2017. Publicly Released: May 17, 2017.
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What GAO Found
The Social Security Administration's (SSA) primary approach for encouraging employment for transition-age youth (ages 14 to 17) with disabilities who receive Supplemental Security Income (SSI) is work incentives that allow them to keep at least some of their SSI benefits and Medicaid coverage while they work. But few transition-age youth benefit from these incentives. SSI is a means-tested program that provides cash benefits to eligible low-income aged, blind, and disabled individuals. SSA administers several work incentives that allow SSI recipients to exclude some income and expenses when calculating SSI benefits. The work incentive targeted specifically to younger SSI recipients is the Student Earned Income Exclusion (SEIE), which allows income to be excluded from benefits calculations if a recipient is a student under age 22. However, less than 1.5 percent of all transition-age youth—and generally less than half of those with earnings—benefited from SEIE in 2012 through 2015. SSA does not analyze these data, and thus cannot determine why the majority of youth with earnings are not benefiting from SEIE, when they may be eligible. SSA data also show that almost no youth benefited from other incentives that allow them to exclude earnings used for specific purposes, such as the Impairment-Related Work Expenses incentive. The effectiveness of SSA-administered work incentives may be further limited because, according to SSA and other officials, youth and their families are often unaware of or do not understand them, and may fear that work will negatively affect their benefits or eligibility. SSA policy requires staff to provide accurate and meaningful information about relevant SSI policies to claimants and recipients. However, GAO found that SSA does not have sufficient procedures in place to ensure that information on work incentives and how work affects benefits and eligibility is consistently communicated to youth and their families. As a result, SSA may miss opportunities to promote work incentives and other supports, allay fears, and potentially reduce dependence of transition-age youth on SSI benefits.
SSA does not have a systematic way to connect transition-age youth on SSI to state Vocational Rehabilitation (VR) agencies that provide training and employment services under the VR State Grants program administered by the Department of Education (Education). Although youth receiving SSI are generally presumed to be eligible for VR services, GAO found that less than 1 percent had an open VR service record in 2015 in four of the five states from which GAO collected VR data. Legislation in 1999 created the Ticket to Work and Self-Sufficiency program, which expanded the number and types of employment service providers for individuals with disabilities. However, SSA limited eligibility to recipients age 18 and older. While transition-age youth receiving special education services can be connected to VR agencies through their schools, the extent to which this happens—and whether they are on SSI—is unknown because data to make such determinations are not systematically collected by SSA or schools. Federal standards for internal control call for agencies to use quality information to achieve their objectives. Without relevant data or additional options for connecting youth to VR services, SSA cannot ensure that transition-age youth on SSI are being connected to these services, which can help to prepare them for adulthood and the workforce.
Why GAO Did This Study
The number of individuals with disabilities under age 18 receiving SSI benefits increased by about 44 percent from 2000 through 2016. Youth ages 14 to 17 with disabilities face many challenges achieving self-sufficiency as they transition to adulthood. GAO was asked to examine SSA's efforts to encourage employment for these transition-age youth.
This report examines 1) SSA efforts to encourage employment for transition-age youth on SSI as they move toward adulthood and their effectiveness; and 2) the extent to which SSA helps ensure these youth receive vocational rehabilitation services. GAO analyzed SSA data on work incentives for calendar years 2012-2015, the most recent available, and data from five state VR agencies for calendar year 2015; reviewed relevant laws, policies, and research; and interviewed SSA staff and state VR officials in several states chosen for their SSI youth populations and VR outcomes.
What GAO Recommends
GAO recommends SSA 1) analyze why youth on SSI with earnings did not benefit from SEIE, 2) improve communication about work incentives and rules, 3) work with Education to determine how many youth on SSI are not connected to VR services, and 4) explore options to further connect them. SSA agreed in whole or in part with three recommendations. SSA disagreed that its communication on work incentives and rules needs to be improved, stating field staff provides information to youth, and it has created new written material. GAO maintains SSA's communication could be improved as presented in this report.
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Recommendations for Executive Action
Comments: SSA agreed with this recommendation. In August 2018, the agency reported that it is in the process of evaluating the accuracy of its SEIE data and once completed, the agency plans to analyze these data to determine whether there are significant numbers of students with earnings who are not benefiting from the SEIE. SSA also reported that it has a legislative proposal in the fiscal year 2019 Presidential Budget that would eliminate earnings reporting for youth, which would prevent similar concerns in the future. In June, 2019, SSA reported that it is continuing to analyze its SEIE data. GAO will close this recommendation when SSA analyzes SEIE data and, if warranted, takes actions needed to ensure those eligible for SEIE benefit from it; or when all students with earnings receive SEIE because SSA's legislative proposal was enacted.
Recommendation: The Acting Commissioner of the Social Security Administration should analyze the SEIE data to determine why a large proportion of transition-age youth on SSI with reported earnings did not benefit from the SEIE and, if warranted, take actions to ensure that those eligible for the incentive benefit from it.
Agency Affected: Social Security Administration
Comments: SSA disagreed with this recommendation. In August 2018, SSA noted it already requires staff to meet with SSI recipients regularly and instructs staff to discuss relevant work incentives, and that there is no indication that staff are not providing youth with appropriate work incentive information. However, SSA did not explain how it knows or ensures that staff are providing this information and SSA policies do not instruct staff to consistently convey information to youth and families on how work may or may not affect age 18 redetermination. SSA also reported that Work Incentives Planning and Assistance (WIPA) projects must prioritize working with youth who are referred to them. While we recognize the important role that WIPA projects play in providing work incentives counseling to SSI youth, as we previously reported, WIPA projects have limited capacity for serving youth along with other SSI recipients and disability insurance beneficiaries. SSA also reported in August 2018 that it planned to send a recently-updated brochure-containing information in English or Spanish on age-18 redeterminations, impact of earnings on benefits, work incentives and contact information-to over 350,000 transition-age SSI recipients. In June 2019, SSA reported it further updated this brochure to include information on SSA work incentives that may allow recipients who work to keep their Medicaid benefits. While this is a positive step, we previously reported that written information may not be sufficient for conveying complex information. As of June 2019, SSA continued to disagree with this recommendation, noting that the specific strategy suggested in the recommendation is too resource consuming given the current state of its operational workloads. We acknowledge that it may be challenging for SSA to ensure staff across its offices consistently and accurately explain complex program rules pertaining to work and work incentives. At the same time, field office staff are both obliged and best-positioned to explain these rules. Moreover, in response to an SSA request for Information, SSA received a range of feedback on how it might improve transition outcomes for youth on SSI through better communication, suggesting that SSA's current communication strategies may not be sufficiently effective. We will consider closing this recommendation when SSA has taken further steps to ensure field staff are providing consistent and accurate information.
Recommendation: The Acting Commissioner of the Social Security Administration should analyze options to improve communication about SSA-administered work incentives and the implications of work on SSI benefits, with a goal of increasing understanding of SSI program rules and work incentives among transition-age youth and their families. This should include, but not necessarily be limited to, updating SSAs procedures for staff meeting with SSI applicants, recipients, and their families to regularly and consistently discuss - when applicable--how work incentives can prevent reductions in benefit levels and how work history is considered during eligibility redeterminations.
Agency Affected: Social Security Administration
Comments: SSA partially agreed with this recommendation but, after discussing it with the Department of Education (Education), reported that obstacles prevent its implementation. In August 2018, SSA officials reported they had discussions with Education about how to determine the extent to which schools are not providing transition services to youth on SSI. SSA concluded there are legal and operational barriers to sharing data on SSI receipt with schools to facilitate the school's ability to connect youth on SSI with vocational rehabilitation services. In September 2018, SSA further reported that existing surveys will not provide data to address this recommendation because these surveys no longer reflect the substantial changes to youth transition environment under the WIOA programs. In addition, SSA said that to share data, SSA would need to develop an agreement with each individual LEA because Education does not have universal data. Even if data could be shared, SSA states that it does not have the legal authority to refer SSI recipients to vocational rehabilitation outside of demonstration projects. As of June 2019, SSA officials continued to report they would continue to work with Education elsewhere on this issue, while signaling the agency does not plan further action to implement this recommendation. However, unless SSA takes steps to overcome the legal and operational barriers it identified to sharing data on youth receiving SSI, or can monitor its success at connecting to VR services through implementation of our fourth recommendation, SSA cannot know whether youth on SSI are receiving or have access to services they may need to achieve employment and, potentially, self-sufficiency. We maintain that SSA should remain open to identifying opportunities to determining the extent of youth not connected to VR, and reviewing options with Education as Education's implementation of WIOA and data collection on youth in transition evolves.
Recommendation: The Acting Commissioner of the Social Security Administration should work with the Secretary of Education to determine the extent to which youth on SSI are not receiving transition services through schools that can connect them to VR agencies and services.
Agency Affected: Social Security Administration
Comments: SSA agreed with this recommendation and, in August 2018, SSA officials reported that they had taken several steps to explore and pursue options for increasing youth's connections to vocational rehabilitation agencies and services. Specifically, officials reported they published a request for information (RFI) in the Federal Register seeking strategies to improve the economic outcomes for youth on SSI when they transition to adulthood. The request for information published in January 2018 explicitly asks, among other things, about ways to connect youth receiving SSI with vocational rehabilitation agencies and about options for programs like a Ticket to Work for youth. In July 2019, SSA reported that it received almost 200 responses to its RFI and has analyzed these responses. SSA plans to continue to share the responses internally and discuss its findings with federal partners and stakeholders. Among other steps, the agency plans to convene a Technical Expert Panel to examine a potential youth ticket to work demonstration.In August 2018, SSA officials reported that, after reviewing its interpretation of the Social Security Act, the agency continues to maintain that the law precludes it from directly or indirectly referring youth on SSI to vocational rehabilitation agencies. Therefore, SSA submitted a legislative proposal in the 2019 Presidential Budget that would allow the agency to refer youth to vocational rehabilitation agencies. SSA officials also reported that SSA started two demonstration projects to determine whether youth on SSI benefit from referrals to vocational rehabilitation agencies. According to information provided in July 2019, one of these projects analyzes an experimental intervention to improve the outcomes of children receiving SSI by providing personalized information to families about the likelihood that a child will not continue on SSI after age 18 redetermination, as well as resources to help these youth with the transition to employment. The resources offered will include: math tutoring, SAT/ACT test preparation, and help with applying for vocational rehabilitation services. SSA's second demonstration project, which has not yet begun, will involve testing direct referrals to VR in one state for 18 and 19 year olds who or may become SSI or Social Security Disability Insurance beneficiaries. This demonstration project will involve data sharing between SSA and the state on individuals eligible to participate in the project. SSA's actions are positive steps and we will continue to monitor SSA's progress related to its Technical Expert Panel and demonstration projects.
Recommendation: The Acting Commissioner of the Social Security Administration should explore various options for increasing connections to VR agencies and services, including their potential costs and benefits. One option, among others, could be to expand the Ticket to Work program to include youth.
Agency Affected: Social Security Administration