Supporting Statement--0644

Supporting Statement for

The Ticket to Work and Self-Sufficiency Program

20 CFR 411

OMB No. 0960-0644

A.Justification

1. This collection is necessary to administer the Ticket to Work Program authorized under Section 1148 of the Social Security Act, which provides Social Security Disability Insurance (SSDI) and Supplemental Security Income (SSI) beneficiaries with expanded options for access to employment services, vocational rehabilitation services, and other employment-related support services as they work towards decreased dependence on government cash benefits. The Ticket to Work Program allows SSDI and SSI beneficiaries to choose an employment network service provider, who will guide and assist these beneficiaries in reaching their goals to obtain and maintain self-supporting employment.

The regulations for the Ticket to Work Program, including descriptions of the information collection requirements of the program, are codified in 20 CFR 411.100-411.730 of the Code of Federal Regulations. Section 205 (a) of the Social Security Act gives the Commissioner of Social Security the authority to establish regulations for the Social Security Administration’s programs.

2. There are multiple categories of information collection requirements in these regulations. As noted below, there are now two additional collection requirements related to the Amendments to the Ticket to Work and Self-Sufficiency Program (967F). Some sections of the amended regulation retained pre-existing information collection requirements. In addition, we have adjusted the burden hours associated with some of the collections because of the regulatory amendments and program experience.

1. Establishing Ticket Assignments and Ticket Use

There are three ways through which a ticket holder may use his or her ticket with a service provider. Each way requires the service provider, which is either an employment network (EN) or a State vocational rehabilitation agency (State VR agency), to send the Ticket to Work Program Manager (PM) information signifying the relationship that has been established between the agency and the ticket holder.

Individual Work Plans (IWP) – Sections 411.140(d)(3), 411.150(b)(3) and 411.325(a) –require ENs (except State VR agencies acting as ENs) to submit an IWP to solidify a ticket assignment or reassignment and to inform the PM of amendments to the IWP. The IWP outlines the ticket holder’s employment goals and the services the EN agrees to provide to help meet the goals and other information as described in 411.465.

Form SSA-1365 – Sections 411.140(d)(3), 411.385(a) and 411.390 – requires the State VR agency to submit information establishing the ticket assignment using the form we prescribe. This brief form is essentially a signed statement that the State VR agency has developed an individualized plan for employment toward which the ticket holder and the agency agree to work. OMB approved the State Agency Ticket Assignment Form, SSA-1365, under OMB Control No. 0960-0641. However, SSA is now combining the two collections by folding the SSA-1365 into this information collection covering the regulation from which it gets its authority (see Addendum).

Electronic Data Sharing – Amendments to the Ticket to Work and Self-Sufficiency Program (967F) in 411.170(b), 411.358(a), 411.390 – create a new ticket status called the “Cost Reimbursement Option” for when the ticket holder is using the ticket with the State VR agency under the traditional cost reimbursement payment method (i.e. the State VR agency is not acting as an EN). Ticket holders cannot assign tickets in this status to an EN while the State VR agency has the case open. In support of this policy, we will ask State VR agencies to inform us when ticket holders work with them under this option. Instead of an individual paper form, they will report to the PM monthly in an electronic file (common delimited file) the names and Social Security numbers of all the ticket holders with whom they’ve begun working under this option during the reporting period and the effective date of the individualized plan for employment, which signifies the date the ticket is officially in-use with the State VR agency. We are currently in the process of developing this.

2. Requesting Ticket Unassignments and Notifying of VR Case Closures

Section 411.145 and 411.325 requires the beneficiary or the service provider who wants to take a ticket out of assignment to notify the PM. Likewise, in connection with the regulatory amendment mention in a. above, to support 411.535(a)(1)(iii) the State VR agency should inform the PM when it closes the case of a ticket holder that the State VR agency was serving under the cost reimbursement option. These notifications are important to monitor participation in the program and accurately reflect the ticket status of beneficiaries who are eligible to participate in the Ticket to Work Program and the periods of service for which an EN or State VR agency may be credited.

c. Tracking Progress

SSA may not initiate a medical Continuing Disability Review (CDR) while a beneficiary is using a ticket. If a ticket holder has assigned the ticket or is using the ticket with the State VR agency under the cost reimbursement option, at the conclusion of each 12 month period of ticket use, we will request the beneficiary or the service provider to certify whether the ticket holder is making the expected progress. Months in which the ticket is in inactive status do not count towards the 12 month periods of ticket use for timely progress. There are three information collections associated with this provision.

Request to Place Ticket in Inactive Status – Section 411.192(b) and (c) – permits a ticket holder to request in writing that the PM deactivate the ticket and reactivate a ticket during a period in which the ticket holder becomes temporarily unable to make timely progress toward self-supporting employment. Upon receiving such a request, the PM will transmit updated information to SSA so that the inactive or reactivated ticket status will take effect. This information is important so that the beneficiary does not continue to be exempt from receiving a medical CDR while the ticket is inactive and so he or she regains exempt status when the ticket the PM reactivates the ticket.

Request for Certification of Work and Educational Progress – Section 411.200(b) –indicates that if SSA’s administrative records don’t show that the ticket holder has met the work or educational requirement for the timely progress period, the PM will contact the ticket holder by letter requesting that the ticket holder let us know whether he or she has met the progress requirements for the period. If the ticket holder does not respond, the PM will seek certification from the EN or State VR agency via monthly electronic file transfer. SSA uses the SSA-1375 for this purpose.

Request to reenter Ticket-Use Status after Not Making Timely Progress – Section 411.210(b) – requires the ticket holder to send a written request for placement to in-use status after not meeting the timely progress criteria. The PM will decide if the ticket holder has met the applicable requirements. If so, the PM will transmit the updated ticket status change and the beneficiary will once again be exempt from a medical CDR.

4. Selecting a Payment System

Section 411.505 requires ENs to make their selection of a payment system at the time they enter into contract with SSA. Section 411.365 requires State VR agencies to send the PM a letter telling us which EN payment system it chooses when it functions as an EN. Amendments to the Ticket to Work and Self-Sufficiency Program (967F) in 411.515 allow ENs and State VR agencies acting as ENs to change their EN payment system election once in each calendar year. The PM uses the elections and time periods to identify the method of payment appropriate for compensating an EN or State VR agency when they file a request for payment under an EN payment system.

4. Reporting Referral Agreement Activity

Section 411.400 – 411.420 explains that ENs and State VR agencies may have individual and broad-based agreements covering ENs’ referral of beneficiaries, whose ticket assignments they hold, to State VR agencies for services. Section 411.325(d) and 411.415 require that ENs submit the agreements to the PM prior to referring beneficiaries to the State VR agencies.

f. Requesting EN Payments

Section 411.575 requires ENs seeking milestone and outcome payments, including a State VR agency acting as an EN, to send a request for payment to the PM for each milestone or outcome payment attained. The payment request must include evidence of the ticket holder’s work and earnings and or other documentation as required.

g. Reporting Periodic Outcomes

Section 411.325(f) provides that ENs must prepare periodic reports of the specific outcomes achieved with respect to the services the EN has provided ticket holders and make the periodic reports available to each beneficiary with a ticket who agrees to accept services from the EN.

h. Dispute Resolution

The Ticket to Work Program provides a mechanism for dispute resolution when disputes involve beneficiaries, the PM, ENs, and/or State VR agencies. Section 411.435 provides that under certain circumstances ENs and State VR agencies that have a dispute related to an agreement between the two agencies may request the PM to recommend a dispute resolution. Section 411.615 and 411.625 provide that a beneficiary or EN may advance a dispute resolution request to the PM and then to SSA.

3. We are using applicable automation when possible. To the extent possible, the PM will accept information from sources using electronic information technology. We are in the process of developing electronic data sharing for the two largest of the information collections described in this request.

4. SSA does not collect duplicate or similar data.

5. The information collections in this request will not significantly affect a substantial number of small businesses. Currently there are over 1200 ENs under contract with SSA, most of which are small businesses. About a third of them are active partners.

6. If SSA collected the information less frequently, it would not comply with Ticket to Work legislation in some respects, and the cost of operating the program may be adversely affected. In addition, reducing the reporting burden means that SSA could not adequately monitor activities of beneficiaries who are using a ticket. Information gaps could lead to less than adequate oversight of program compliance.

6. To manage the Ticket to Work Program, SSA must have up-to-date information concerning ticket assignments/unassignments and the status of tickets under the cost reimbursement status with State VR agencies. Therefore, we need the information close to the date of the action. Quarterly reporting would be insufficient. Otherwise, this collection is consistent with 5 CFR 1320.

6. SSA published the 60-day advance Federal Register Notice on May 2, 2008 at 73 FR 24340, and SSA has received no public comments. SSA published the second Notice on August 22, 2008, at 73 FR 49730.

Because of the nature of the Ticket to Work Program, the agency regularly consults with the disability community, including advocates, employment networks, State VR agencies and ticket eligible beneficiaries. In response to concerns about the potential administrative burden on service providers that have a large number of ticket holders as clients, we decided to primarily determine administratively and through contact with ticket holders if timely progress they are meeting timely progress requirements. In addition, the electronic data sharing reflected in some of the collections resulted from public comment and consultations.

9. SSA provides no payment or gifts to the respondents.

9. The information provided is protected and held confidential in accordance with 42 U.S.C. 1306, 20 CFR 401 and 402, 5 U.S.C. 552 (Freedom of Information Act), 5 U.S.C. 552a (Privacy Act of 1974) and OMB Circular No. A-130.

11. The information collections in this request do not contain any questions of a sensitive nature.

11. Listed below are the burden hours for each of the information collections included in this request. The total burden is burden hours, and there is no separate cost burden.

a. Establishing Ticket Assignments and Ticket Use

Individual work plans for non-State EN ticket assignments/reassignments:

(Private Sector)

Sections	Annual number of responses	Frequency of response	Average burden of response (minutes)	Estimated annual burden (hours)
411.140(d)(3), 411.150(b)(3), 411.325(a)	3,983	1	240	15,932

Form SSA-1365 State VR agency ticket assignments/reassignments:

(State/local/tribal Government)

Sections	Annual number of responses	Frequency of response	Average burden of response (minutes)	Estimated annual burden (hours)
411.140(d)(3), 411.385(a), 411.390	25,174	1	3	1,259

Electronic data sharing for State VR agency’s tickets under cost reimbursement (data based on annual numbers of cases which both opened and closed per year):

(State/local/tribal Government)

Sections	Annual number of responses	Frequency of response	Average burden of response (minutes)	Estimated annual burden (hours)
411.170(b), 411.385(a), 411.390	35,584	1	5	2,965

b. Requesting Ticket Unassignments and Notifying of VR Case Closures

Unassignments: (Individuals or Private Sector or State/local/tribal Government)

Sections	Annual number of responses	Frequency of response	Average burden of response (minutes)	Estimated annual burden (hours)
411.145, 411.325	2,532	1	15	633

VR Case Closures: (State/local/tribal Government)

Sections	Annual number of responses	Frequency of response	Average burden of response (minutes)	Estimated annual burden (hours)
411.535(a)(1)(iii)	8,505	1	5	709

c. Tracking Progress

Request to Place Ticket in Inactive Status: (Individuals)

Sections	Annual number of responses	Frequency of response	Average burden of response (minutes)	Estimated annual burden (hours)
411.192(b)&(c)	1,000	1	30	500

Request for Certification of Work and Educational Progress: (Individuals or State/local/tribal Government)

Sections	Annual number of responses	Frequency of response	Average burden of response (minutes)	Estimated annual burden (hours)
411.200(b): SSA-1375 Paper Version (Beneficiaries)	13,500	1	15	3,375
411.200(b): SSA-1375 Internet Version (State ENs)	13,500	1	8	1,800

Request to reenter Ticket-Use Status after Not Making Timely Progress: (Individuals)

Sections	Annual number of responses	Frequency of response	Average burden of response (minutes)	Estimated annual burden (hours)
411.210(b)	3,145	1	30	1,573

d. Selecting a Payment System

(Private Sector or State/local/tribal Government)

Sections	Annual number of responses	Frequency of response	Average burden of response (minutes)	Estimated annual burden (hours)
411.365, 411.505, 411.515	118	1	30	59

e. Reporting Referral Agreement Activity

(Private Sector)

Sections	Annual number of responses	Frequency of response	Average burden of response (minutes)	Estimated annual burden (hours)
411.325(d), 411.415	48	1	480	384

f. Requesting EN Payments

(Private Sector or State/local/tribal Government)

Sections	Annual number of responses	Frequency of response	Average burden of response (minutes)	Estimated annual burden (hours)
411.575	12,420	1	60	12,420

g. Periodic Outcomes Reporting

(Private Sector or State/local/tribal Government)

Sections	Annual number of responses	Frequency of response	Average burden of response (minutes)	Estimated annual burden (hours)
411.325(f)	2,470	1	120	4,940

8. Dispute Resolutions

(Individuals/Private Sector or State/local/tribal Government)

Sections	Annual number of responses	Frequency of response	Average burden of response (minutes)	Estimated annual burden (hours)
411.435, 411.615, 411.625	2	1	120	4

Sections	Annual number of responses	Frequency of response	Average burden of response (minutes)	Estimated annual burden (hours)
Totals	121,981			46,553

13. There is no known cost burden to beneficiary respondents, and no known cost burden to business respondents above the customary cost of business recordkeeping equipment.

13. We have not separated cost to collect the information as it is part of the total contract costs.

13. The annual reporting burden for these information collections have changed. We are making a couple program changes from the Amendments to the Ticket to Work and Self-Sufficiency Program (967F) (see Addendum). In general, SSA has adjusted the burden hours based primarily on the use of better management information about the number of respondents and the average burden per response. In addition, the use of electronic data sharing has significantly lowered the burden associated with the two largest information collections in this request. Finally, we are combining this collection with OMB Control No. 0960-0641 (for SSA-1365), which is a program change that increases the burden.

16. SSA will not publish the results of these information collections.

16. SSA is not requesting an exemption from displaying the expiration date for OMB approval of these information collections.

16. SSA is not requesting an exception to the certification requirements at 5 CFR 1320.9 and related provisions at 5 CFR 1320.8(b) (3).

2. Collection of Information Employing Statistical Methods

Statistical methods are not used for these information collections.

Ticket to Work 2/4/2021

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