Tuesday, July 23, 2019

Ticket to Work: Work Incentives

Work Incentives

Work Incentives make it easier for people with disabilities to work and still receive medical benefits and, in some cases, cash benefits from Social Security. Work Incentives can help you through the transition to work and financial independence.

Work Incentives and the Ticket to Work Program

Work Incentives make it possible for you to explore work while still receiving benefits. They are designed to help you succeed!
  • You may be able to keep your Medicaid/Medicare while you work.
  • You have access to individualized support services.
  • You can try work with confidence, knowing you may be able to keep some or all of your benefits during your transition period.
Social Security has many Work Incentives designed to fit your individual situation. For more information about all of Social Security’s Work Incentives and how they can work for you, check out The Red Book – A Guide to Work Incentives.
Here are examples of some of the Work Incentives that may be available to you:
Trial Work Period (TWP)
(SSDI recipients only)
The TWP allows you to test your ability to work for at least 9 months. During your TWP, you will receive full SSDI benefits no matter how much you earn as long as your work activity is reported and you have a disabling impairment.
Expedited Reinstatement(EXR)
(SSDI and SSI recipients)
If your benefits stopped because of your earnings level, and you are no longer able to work because of your medical condition, or one related to it, you can request to have your benefits reinstated without having to complete a new application. While Social Security determines your benefits reinstatement, you are eligible to receive temporary benefits for up to 6 months.
Protection from Medical Continuing Disability Reviews (CDR)
(SSDI and SSI recipients)
If you assign your Ticket to an approved service provider before you receive notice of a medical Continuing Disability Review (CDR), you will not have to undergo the medical review while you are participating in the Ticket to Work program and making progress within Social Security's timeframes.

Learn more about Work Incentives

One of the best ways to learn more about Work Incentives and the Ticket to Work program is to attend a free Work Incentives Seminar Event (WISE) online webinar. The Ticket to Work program hosts an accessible online event for you and your family to learn about Work Incentives, including Ticket to Work. WISE webinars are typically held on the 4th Wednesday of the month. Register online or call 1-866-968-7842 or 1-866-833-2967 (TTY). You can also learn more about Work Incentives in Social Security's Red Book!

Work Incentives for People Who Are Blind

Most people receiving a disability payment can access Work Incentives or employment supports, but some of the rules are more generous if your disability is blindness. Learn more in our resource, Social Security Work Incentives for People who are Blind.

Find out how Work Incentives apply to you

To find out how Work Incentives may apply to you, make an appointment to meet with a benefits counselor at your local Work Incentives Planning and Assistance (WIPA) project. Working with a WIPA project is free for Social Security disability beneficiaries. Visit the Find Help tool to find a WIPA near you or visit our Meet Your Employment Team page for more information.

Friday, July 19, 2019

IEPs and #Transition Planning

  Caution! Is termination of eligibility before transition a good idea?
Advocate Sue Whitney cautions not to allow the school to terminate your child’s eligibility - unless and until - you are convinced that he:
  • is functioning well
  • can get a good job
  • can pursue further education if he wants
from Wrightslaw

Wednesday, July 17, 2019

CMS Administrator Verma Proposes to Repeal the Medicaid Access Rule

For the past two years, CMS Administrator Seema Verma has wanted to “rollback” the Medicaid Access Rule.  That’s the CMS regulation that implements the requirement in the Medicaid statute that rates paid to physicians and other providers be “sufficient” so that enough participate in Medicaid to give beneficiaries access to covered services.   In the spring of 2018, Administrator Verma proposed to partially gut the Access Rule.  About 150 organizations and individuals from 30 states and DC commented; of these, the overwhelming majority (some 90 percent) opposed the proposal. None of the commenters — even those favorable to the proposed gutting — urged repeal of the Access Rule altogether.  
After what was undoubtedly careful consideration of these comments, the Administrator – SURPRISE! – is proposing the repeal the Access Rule altogether.  The public comment period closes September 13, 2019. This repeal dovetails nicely with the reported emphasis by the White House on “faster rollbacks of rules enacted by former president Barack Obama before Trump’s first term ends.” 
Under the proposal, what would be left after the repeal is the same regulatory structure that was first put in place in the early 1980’s: a requirement that the state agency “maintain documentation of payment rates and make it available to HHS [but no one else] upon request” and a requirement that payments be “sufficient to enlist enough providers so that services under the plan are available to beneficiaries at least to the extent that those services are available to the general population in the geographic area.”  This of course, is exactly the same regulatory language that Congress codified in 1989, which, through a long and circuitous route, including two stops at the Supreme Court, led to the promulgation of the Access Rule in November 2015.
The Access Rule contains three requirements for state Medicaid agencies.  These requirements apply only to the fee-for-service portion of a state’s Medicaid program, if any, not to the managed care portion.  First, the agency has to produce an Access Monitoring Review Plan (AMRP) and update date it once every three years. The Plan must analyze access for beneficiaries in fee-for-service Medicaid for six categories of services—primary care, physician specialist, behavioral health, obstetric, and home health—using the data and methodologies selected by the agency.   The first round of AMRPs, completed October 1, 2106, are posted here. Second, if the agency wants to reduce payment rates for a service, it must submit an access review to CMS based on the AMRP that demonstrates sufficient access to the service.  Finally, if the rate reduction is approved by CMS and implemented by the agency, it must monitor access to the service for three years; if the monitoring identifies access deficiencies, the agency must implement a corrective action plan.  That’s it. 
The preamble to the proposed repeal frames these requirements as a policy straightjacket that “excessively constrains state freedom to administer the program in the manner that is best for the state and Medicaid beneficiaries in the State.”  Just to be clear, if the Access Rule is repealed, states would have the freedom to cut fee-for-service provider rates without an access review and without monitoring the effect of the rate cut on access to the affected providers. And in states that base their managed care payment rates on fee-for-service rates, the cut in fee-for-service rates could result in a reduction in capitation rates.  (The Administrator has also pledged to “roll back” administrative burden in the Managed Care Rule).
Of course, how repeal plays out depends on what follows it.  So what exactly will replace the repeal? And when will the repeal be replaced?  According to a CMCS Informational Bulletin,  , instead of the Access Rule, CMS is “setting out a new approach to understanding access and ensuring statutory compliance while eliminating unnecessary burden on states.”  If the repeal is finalized, the agency will issue a letter to State Medicaid Directors to “provide information on data and analysis that states may submit with SPAs to support compliance with [the Medicaid statute’s payment sufficiency requirement].”  Note the “may,” not “must”. Also, “in the upcoming months,” CMS will also be convening workgroups and technical expert panels to assist it in developing a “streamlined, comprehensive approach to monitoring access across Medicaid delivery systems by identifying uniform access indicators that may be measured through available data.”  
The Informational Bulletin provides no timeframe for the development of its new approach to access, much less implementation. The only dates that are clear are the close of the public comment period on the Administrator’s repeal proposal—September 13, 2019—and the date that the next round of AMRP updates is due under the current Rule (October 1, 2019).  Nor does it give any indication that beneficiaries will be among the “key state and federal stakeholders” to be consulted in the development process. Finally, the Bulletin does not explain why new workgroups are needed when the nation already has a Medicaid and CHIP Payment and Access Commission (emphasis added).
Eight years ago, MACPAC published a framework for looking at access (and quality) in Medicaid that has guided its work since then.   And when the Administrator proposed to partially gut the Access Rule last spring, MACPAC commented. Among its concerns: “Rather than eliminate obligations to monitor access, requirements should be targeted in a way that is efficient and effective. To that end, we encourage CMS to look toward how access monitoring plans [required by the Access Rule] can be improved as states gain experience and how these tools can be best used to provide meaningful and actionable information.”
There’s more than a little irony here.  As we all know, Administrator Verma is more than fine with imposing administrative burden on beneficiaries, especially those beneficiaries with the temerity to be “able bodied.”  That’s because red tape demonstrably reduces coverage, which undermines access.  Yet she is proposing the repeal the Access Rule in order to ease “the administrative burden on States while focusing on holding them accountable for delivering high-quality, accessible care to beneficiaries.” The whole point of the Access Rule, of course, is to ensure that state Medicaid agencies and CMS know whether care is actually accessible to beneficiaries in fee-for-service and to hold the agencies accountable if it is not.
There’s a word for this

Tuesday, July 16, 2019

Ticket to Work: How It Works

How It Works

Ticket to Work connects you with free employment services to help you decide if working is right for you, prepare for work, find a job or maintain success while you are working. If you choose to participate, you will receive services such as career counseling, vocational rehabilitation, and job placement and training from authorized Ticket to Work service providers, such as Employment Networks (EN) or your State Vocational Rehabilitation (VR) agency. The service provider you choose will serve as an important part of your "employment team" that will help you on your journey to financial independence.

Who Qualifies?

icons for SSDI and SSIEveryone age 18 through 64 who receives Social Security Disability Insurance (SSDI) and/or Supplemental Security Income (SSI) benefits because of his or her disability is eligible to participate in the Ticket to Work program. Participation in the Ticket to Work program is free and voluntary.
Social Security no longer sends paper Tickets in the mail, and you don't need a paper Ticket to participate! Your eligibility will be verified by the service provider with whom you choose to work. You can also find out about your eligibility status by calling the Ticket to Work Help Line at 1-866-968-7842 /1-866-833-2967 (TTY).

How to Get Started

If you decide to participate, getting started is easy! First, call the Ticket to Work Help Line at 1-866-833-7842 / 1-866-833-2967 (TTY) to verify your eligibility. Our customer service representatives will explain to you how the program works and answer any questions or address any concerns you might have. They will also offer to mail you a list of service providers, or if you prefer, you can use the Find Help tool to get a customized list of providers that are available to help you.
The next step is deciding what service provider is right for you. You may work with either an Employment Network (EN) or your state Vocational Rehabilitation (VR) agency, depending on your needs. The "Finding an EN and Assigning Your Ticket Worksheet" can help you keep track of the ENs you are interested in and provides important questions for you to ask. You may also receive services from your VR agency and then receive ongoing services from an Employment Network.
Some ENs are also part of a state’s public workforce system. These workforce ENs provide access to additional employment support services including training programs and special programs for youth in transition and veterans. A Ticket to Work participant who assigns their Ticket to a workforce EN will either work with a workforce EN directly or via other providers in the workforce system, including American Job Centers.
Once you and your service provider decide to work together, you will collaboratively develop a plan to help you reach your work goals. Your employment team will then help you make progress towards those goals and, eventually, a more financially independent future.

Making Timely Progress After You Assign Your Ticket

Your road to employment through the Ticket program is a two-way street: You receive free assistance from your service provider to prepare for, find and keep a job, while you work your way towards financial independence. In return, you pledge to Social Security that you will take specific steps – determined by the plan you developed with your service provider – within specific timeframes set by Social Security to:    
  • Work at a specified earnings level or,
  • Complete certain educational or training requirements. 
When you participate in the Ticket program, you are working with your EN or VR to reduce or eliminate your dependence on SSDI and/or SSI cash benefits.
Taking the agreed-upon steps toward employment within Social Security’s timeframes is called making “timely progress” towards:  
  • Receiving the education and training you need to succeed at work and your long-term career
  • Becoming and staying employed
  • Reducing your dependence on SSDI or SSI payments
  • Earning your way off cash benefits, if possible
For you, the return for making “timely progress” is that you succeed in achieving a more financially independent life.
Ordinarily Social Security reviews your medical condition from time to time to see whether you still have a disability through a process called the medical Continuing Disability Review, or CDR. If you assign your Ticket to an approved service provider before you receive a CDR notice and make “timely progress” following your employment plan, Social Security will not conduct a review of your medical condition.  If you assign your Ticket after you receive a CDR notice, Social Security will continue with your scheduled medical review.

I'm Interested! What's Next?

Here are four actions you can take right now to learn more about the Ticket to Work program and Social Security’s Work Incentives:

Crisis Planning

from NAMI:

For people who are gravely disabled or in immediate danger to themselves or others:
Call 911 and ask for a CIT Officer
For people thinking about suicide, call the National Suicide Prevention Lifeline:
For NAMI Indiana telephone support to help plan for an impending crisis:
Monday-Friday, 9:00 a.m. to 5:00 p.m.
For families who want to prepare for a crisis:
The most important thing a family member can do is provide information. The following forms should be printed and filled-out in the case that a loved one suffers a psychiatric crisis:
When a person is in a psychiatric crisis, it is imperative to be able to get him or her into treatment as quickly as possible. This can present a very significant challenge that we hope our booklet, Planning for and Responding to a Mental Health Crisis, will help you meet successfully.

Friday, July 12, 2019

Don't Let the #Transition Plan Fail Your Child

Take a look at your child's IEP and transition plan.
  • Be sure you are clear of what the goal of her IEP is, as it is written.
  • Are her transition goals appropriate?
  • Has the school failed to provide what is required in the IEP?
Even if the IEP does not require more than has been provided, maybe it should.

from Wrightslaw




(A)Factors contributing to the growth of health care costs, including the following:

(i) The current trends in health care delivery and Indiana's progress in implementing new approaches, including value-based medicine and other alternative payment models.

(ii) Access to health care in rural areas.

(iii) The impact of Indiana's poor health status, the social determinates of health, and the rate of the uninsured on health care costs.(Source: Letter from Rep. Kirchhofer; Rep. Carbaugh; Rep. Shackleford; Rep.Austin; Sen. Ruckelshaus; Sen.Bassler; and Sen. Spartz.)

(B)Prescription drug pricing and access, including the following:

(i) The process in which a prescription drug moves through the supply chain to the consumer, including the role of pharmaceutical manufacturers,wholesale distributors, pharmacies, specialty pharmacies, health insurers,and pharmacy benefit managers.

(ii) The methods that health insurers and pharmacy benefit managers currently use to manage prescription drug costs.

(iii) The function of pharmaceutical manufacturer rebates and discounts used by health insurers and pharmacy benefit managers to decrease the cost of a prescription drug for a consumer.

(iv) The current trends in health care spending in the United States,including prescription drug spending.

(v) The trends in insurance benefit design and the potential impact that changes are having or may have on consumer out-of-pocket costs for prescription drugs.

(vi) The efforts that pharmaceutical manufacturers, health insurers, and pharmacy benefit managers have made to be transparent about the following:
(a) Prescription drug costs.
(b) Utilization management methods, including drug formulary
changes, prior authorization, and step therapy requirements. (Source: SEA 176-2019.)(C)The following:(i) The advantages, disadvantages, and feasibility of requiring health care providers to issue prescriptions in an electronic format and by electronic transmission(ii) Any exceptions that would be needed to a requirement for health care providers to issue prescriptions in an electronic format and by electronic transmission.(Source: HEA 1029-2019.)

(D)Regulation and practices of pharmacy benefit managers. (Source:HEA 1588-2019.)

(E)Authorization of an advance practice registered nurse to operate without a practice agreement with a physician or certain other practitioners. (Source: SB 394-2019(as printed February 8, 2019); SB 343-2019 (as introduced).)

(F)The following hospital licensure issues:(i) A review of Indiana's current hospital licensing structure.(ii) Information concerning other states' hospital licensure and nationaltrends.(iii) Information concerning the different types of hospitals and possibleclassifications, including subclassifications, of these hospitals through thehospital's license.(vi) An examination of state hospital licensure in the context of federallaw, regulations, policies, and conditions of participation in the Medicareand Medicaid programs.(Source: SEA 575-2019.)

(G)Adoption subsidies. (Source: Letter from Senator Niezgodski