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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.


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.

Recommendations for Executive Action

Agency Affected Recommendation Status
Social Security Administration 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.
Closed – Implemented
SSA agreed with this recommendation. In August 2018, the agency reported that it was evaluating the accuracy of its SEIE data and once completed, the agency would analyze these data to determine whether there are significant numbers of students with earnings who are not benefiting from the SEIE. As of March 2021, SSA had resolved issues with its SEIE data identified during GAO's audit and had completed its analysis of the data. SSA officials confirmed that most students with earnings have neither a student indicator nor an SEIE on their record and are thus not receiving the income exclusion for which they are eligible. As a result of this analysis, in June 2021, SSA issued an Administrative Message to its field office technicians reminding them to properly screen for and apply the SEIE to ensure that those eligible for the incentive benefit from it. Further, SSA submitted legislative proposals in several Presidential Budgets, most recently in fiscal year 2021, that would eliminate earnings reporting for youth, which would prevent similar concerns in the future.
Social Security Administration 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.
Closed – Implemented
SSA initially 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. Nevertheless, SSA ultimately took steps consistent with this recommendation. In June 2019, SSA reported it had updated a related brochure-containing information in English or Spanish on age-18 redeterminations, impact of earnings on benefits, work incentives, and contact information-that it sends annually to transition-age youth receiving SSI. The brochure now includes: 1) information on SSA work incentives that may allow recipients who work to keep their Medicaid benefits, and 2) a new section titled "Earnings and the Age-18 Redetermination" that explains how SSA considers earnings in the redetermination process. In November 2020, SSA issued an Administrative Message to its field office, Teleservice Center, and Program Service Centers, among other SSA components, notifying them that this updated brochure was mailed to the parents and guardians of all SSI recipient ages 14 through 17, and instructing them on how to respond to beneficiary questions about it.
Social Security Administration 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.
Closed – Implemented
SSA took steps to determine the extent to which youth on SSI are receiving transition services to connect them to VR agencies and services. In January 2022, SSA reported that it has been evaluating newly available VR data on pre-employment transition services-services that state VR agencies provide to youth with disabilities in schools and other settings-which Education has been collecting since 2017. SSA reported, however, that Social Security numbers (SSNs) were missing from about half of youth records and attributed missing SSNs to state VR agencies not requiring and inconsistently collecting SSNs for youth clients. Education officials confirmed VR agencies are not required to collect SSNs because SSNs are not needed to provide services, and stated that collecting them may unnecessarily pose a risk to student privacy. Due to this issue, SSA reported it is unable to readily use Education's data to analyze the extent to which youth on SSI are receiving transition services. Although issues prevent SSA from analyzing Education's VR data, SSA reported in December 2019 that it continues to support research to identify the connection between youth on SSI and the receipt of VR services through its Retirement and Disability Research Consortia and its Analyzing Relationships Between Disability, Rehabilitation, and Work programs. SSA's actions fully address GAO's recommendation to work with Education on this issue; however, as available data or circumstances evolve, GAO encourages SSA to continue to explore options for determining the extent to which youth on SSI are not receiving transition services to connect them to VR through schools.
Social Security Administration 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.
Closed – Implemented
SSA agreed with this recommendation and took steps to explore and pursue options for increasing youths' connections to vocational rehabilitation (VR) agencies and services. In January 2018, SSA published a request for information (RFI) in the Federal Register that, among other things, solicited strategies for connecting youth receiving Supplemental Security Income (SSI) with vocational rehabilitation agencies, including options for programs like a Ticket to Work for youth. In July 2019, SSA reported receiving and analyzing almost 200 responses to its RFI. Based on RFI comments, SSA initiated a demonstration project in January 2020 to determine whether youth on SSI would benefit from referrals to VR. This project was designed to test the effectiveness of direct referrals to VR in one state for 18 and 19 year olds who are or may become SSI or Social Security Disability Insurance beneficiaries. Separately, SSA officials initiated another demonstration to improve the outcomes of children receiving SSI. According to SSA, the demonstration provides personalized information to families about the likelihood a child will not continue on SSI as an adult and resources to help these youth with the transition to employment. The resources offered will include help applying for vocational rehabilitation services. In addition, SSA commissioned two reports, published in February and March 2020. These reports identified evidence and made recommendations to design regulatory and policy changes that support employment for youth with disabilities. They also synthesized available evidence on the effect of community-based services and supports for transition-age youth with disabilities. The March 2020 study, which focused on evidence on youth employment, had some similar findings and recommendations to those made by GAO. Lastly, SSA officials previously reported that the agency has reviewed the Social Security Act and that the law precludes SSA from directly or indirectly referring youth on SSI to vocational rehabilitation agencies. SSA included a legislative proposal in presidential budgets for 2019, 2020, and 2021 that would allow it to directly refer youth to vocational rehabilitation agencies. In December 2021, SSA stated that, based on research it has conducted, the agency continues to maintain that direct referrals to VR are the best and only realistic option for directly increasing connections to VR. While SSA's actions fully address GAO's recommendations to explore options, GAO encourages SSA to continue efforts that may result in implementing a mechanism for further connecting youth on SSI with VR services.

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