Work Incentives Protecting Health Coverage for People with Disabilities

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by Lesley Lopez                      

Many SSA beneficiaries are afraid of losing their health insurance coverage because of employment, however, SSA provides protections to SSA beneficiaries to be able to work and keep their Medicare or Medicaid.

Extended Medicare Coverage for Working People with Disabilities. Beneficiaries receiving SSDI

As long as your disabling condition still meets our rules, you can keep your Medicare coverage for at least 8 ½ years after you return to work. (The 8 ½ years includes your nine month trial work Period)

Your Medicare hospital insurance (Part A) coverage is premium-free. Your Medicare medical insurance (Part B) coverage will also continue. You or a third party (if applicable) will continue to pay for Part B. If your Social Security Disability Insurance cash benefits stop due to your work, you or a third party (if applicable) will be billed every 3 months for your medical insurance premiums. If you are receiving cash benefits, your medical insurance premiums will be deducted monthly from your check.

Continued Medicaid Eligibility (Section 1619(B))

For beneficiaries receiving SSI

One of the biggest concerns SSI beneficiaries have about going to work is the possibility of losing Medicaid coverage. Section 1619(b) of the Social Security Act provides some protection for these beneficiaries. To qualify for continuing Medicaid coverage, a person must:

  • Have been eligible for an SSI cash payment for at least 1 month;
  • Still meet the disability requirement; and
  • Still meet all other non-disability SSI requirements; and
  • Need Medicaid benefits to continue to work; and
  • Have gross earnings that are insufficient to replace SSI, Medicaid and publicly funded attendant care services.

This means that SSI beneficiaries who have earnings too high for a SSI cash payment may be eligible for Medicaid if they meet the above requirements. SSA uses a threshold amount to measure whether a person’s earnings are high enough to replace his/her SSI and Medicaid benefits. This threshold is based on the:

  • amount of earnings which would cause SSI cash payments to stop in the person’s State; and
  • Average Medicaid expenses in that State.

If an SSI beneficiary has gross earnings higher than the threshold amount for his/her State, SSA can figure an individual threshold amount if that person has:

The state of Florida 2016 annual threshold amounts for disabled and blind beneficiaries is $30,566

Other health care options:

Market Place or Affordable Care Act

A service that helps people shop for and enroll in affordable health insurance. The federal government operates the Marketplace, available at HealthCare.gov, for most states. Some states run their own Marketplaces.

The Health Insurance Marketplace (also known as the “Marketplace” or “exchange”) provides health plan shopping and enrollment services through websites, call centers, and in-person help.

When you apply for individual and family coverage through the Marketplace, you’ll provide income and household information. You’ll find out if you qualify for:

  • Premium tax credits and other savings that make insurance more affordable
  • Coverage through the Medicaid and Children’s Health Insurance Program (CHIP) in your state

On HealthCare.gov, you may be asked to select your state or enter your ZIP code. If you live in a state that runs its own Marketplace, we’ll send you to your state’s Marketplace website.

 Medicaid Share of Cost or Medically Needy

The Department of Children and Families (DCF) determines eligibility for the Medically Needy Program. It may also be referred to as the “Share of Cost” program. The Medically Needy Program assists individuals who would qualify for Medicaid except for having income that is too high. Individuals enrolled in Medically Needy may have a monthly “share of cost,” which is similar to an insurance deductible. The share of cost is determined by household size and gross monthly income. When there are changes to the household size and income, the share of cost amount may change.

Some examples of medical expenses that can be used to meet the “share of cost”

  • Unpaid medical bills owed that have not been used to meet the share of cost before.
  • Medical bills the individual paid within the last three months.
  • Health insurance premiums
  • Medical bills that will not be paid by health insurance or any other source.
  • Co-pays for medical bills.
  • Medical services prescribed by a doctor.
  • Transportation by ambulance, bus or taxi to get medical care.

For more information about the Medicaid share of cost please visit http://www.myflorida.com/accessflorida/

 Community Health clinics (CHI)

Community Health of South Florida Inc. is a non-profit health care organization providing affordable quality primary and behavioral health care services to the residents of rapidly growing South Florida. CHI operates 11 state-of-the-art primary care centers and 31 school-based programs. All centers offer quality comprehensive primary and behavioral health care services. Our physicians are board certified or board eligible. Additionally, CHI is accredited by the Joint Commission and is accredited as a Level 3 Patient-Centered Medical Home by the National Committee for Quality Assurance (NCQA). CHI offers a “one-stop-shop” model where the organization and delivery of quality services are seamless, affordable, accessible and culturally sensitive.

For more information visit the website http://www.chisouthfl.org/

If you are a SSI or SSDI beneficiary and needs an individualized analysis of your situation please contact the Community Work Incentives Coordinator or benefits Planner in your area.  Please check the SSA Website for more details: http://choosework.net.

What is a Community Work Incentives Coordinator (CWIC) or benefits planner?

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By: Lesly Lopez

If you receive Social Security benefits and you have a job or are looking for one, there are specially trained professionals known as Community Work Incentive Coordinators (CWIC) to help you make sense of complex employment and benefit-related issues.

What is a CWIC?

A highly skilled and rigorously trained cadre of Community Work Incentives Coordinators (CWICs) provide individual counseling to beneficiaries seeking employment and intensive follow-up services to ensure that they are using the work incentives appropriately. CWICS provide confidential services to people with disabilities who receive Supplemental Security Income (SSI) and/or Social Security Disability Income (SSDI). CWICs educate beneficiaries on how employment will affect their public benefits such as SSI, SSDI, Medicare, Medicaid, subsidized housing and food stamps.
CWICs are funded through the Social Security Administration grant called WIPA, Work Incentives Planning and Assistance. CWICs are not SSA employees. However, they do serve SSI and SSDI beneficiaries, including young adults who are transitioning from school to work.

What a CWIC can do for you?

• Help you understand how working and earning wages will affect your public benefits
• Provide ongoing assistance to help you manage your benefits as you transition into employment or increase your earnings
• Provide information on available education, training, and employment services
• Help develop and implement PASS Plans and other Work Incentives that assist you to achieve your employment goal
• Understand the rules of specific Work Incentives and how they apply to you
• Decide whether the Ticket to Work program is right for you
• Understand the potential benefits of employment as a person who receives disability benefits from Social Security while dispelling the myths about working
• Analyze how work and earnings may impact your Supplemental Security Income (SSI), Social Security Disability Insurance (SSDI), health care, and other public benefits
• Understand the services provided by a State Vocational Rehabilitation (VR) agency or an Employment Network (EN), and how they might fit best with your needs
• Teach about the work incentives from SSA to beneficiaries and community partners.
• enhance self-sufficiency
• ensure informed choices,
• get rid of fear in pursuing employment
• problem solving and advocacy,
• benefits analysis and advisement/benefits support, planning/benefits management and
• Information and referral about other resources available to you in the community.

For additional questions please call the TTW help line at 1-866-968-7842 / 866-833-2967 (TTY) Monday through Friday from 8:00AM – 8:00PM EST. For general inquiries, you may e-mail support@chooseworkttw.net.

The PASS Plan

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By: Lesly Quin

How a PASS plan can help you?
A PASS (Plan for Achieving Self Support) allows you to set aside other income besides your Supplemental Security Income (SSI) and/or resources for a specified period of time so that you may pursue a work goal that will reduce or eliminate the SSI or Social Security Disability Insurance (SSDI) benefits you currently receive.

Who can have a PASS?
If you receive SSI or could qualify for SSI after setting aside income or resources so that you may pursue a work goal, you could benefit from a PASS.

Requirements for a PASS:
Be designed especially for you;
Be in writing. Using the form, the SSA-545-BK.You can get copies of the PASS form from http://www.socialsecurity.gov/online/ssa-545.html;
Have a specific work goal that you are capable of performing;
Have a specific timeframe for reaching your goal;
Show what income you receive (other than your SSI payments) and/or resources you have that you will use to reach your goal;
Show how you will use your income and resources to reach your work goal;
Show how the money you set aside will be kept separate from other funds;
Be approved by us; and
Be reviewed periodically by us to assure your plan is actually helping you make progress towards your work goal.

What can I purchase with a PASS?
The money you save in a PASS can be for education, vocational training, starting a business, or buying support services that enable you to work. This includes assistive technology to help you with your employment goal. With a PASS plan you can save to purchase assistive technology such as:
– Equipment and supplies you need to establish and carry on a trade or business;
– Equipment or tools you need because of your condition or for your job;
– Modifications to buildings and vehicles to accommodate your disability;

Can I get help to complete the PASS application?
You should write your PASS with the help of a rehabilitation specialist, such as a Department of Rehabilitation counselor. SSA has contracted with local organizations to provide benefits planning. Some of these organizations may be able to assist with completing a PASS application. For more information about the Work Incentives Planning Assistance, go to: http://www.ssa.gov/work/WIPA.html
Also, the PASS Cadre is required to keep a list of agencies that can help with completing the PASS application.
Tips for Success:
• Connect with your local Work Incentive Planning and Assistance project to better understand this work incentive as well as other work incentives available to assist you in your return to work:
• Contact a PASS Cadre
Other things to know about PASS plans:
You can use any money for a PASS plan other than SSI.
If setting aside your SSDI (Social Security Disability Insurance) would allow you to meet SSI’s income requirements, then you could qualify for both SSI and PASS. (You will need to show that you can live on the SSI payment and that you will be able to use your other income to pay for the items and services you need to achieve your goal.)
To build assets for your PASS plan, you will open a PASS account with your local bank. A PASS account is a checking account that will be used for all your PASS plan banking transactions.

For more information on Plans for Achieving Self Support:
Social Security Administration – http://www.socialsecurity.gov/disabilityresearch/wi/pass.htm

Cornell University Employment and Disability Institute – http://www.passonline.org/

The University of Montana Rural Institute – http://www.passplan.org
Institute for Community Inclusion – http://www.communityinclusion.org/article.php?article_id=66

Work World – http://www.workworld.org/wwwebhelp/pass.htm

Subsidies for SGA

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Are you a SSDI beneficiary working or wanting to work over the Substantial Gainful Activity ($1090 in 2015)? Are you receiving support from your employer? You can use Subsidies for SGA purposes

A few things to consider first: During an SGA determination, SSA looks at gross wages when they were earned, not when they were paid to you. For example, if you get paid every week or every other week you will have some months when you get an extra paycheck. SSA won’t count that extra paycheck when it was received – they are only interested in when the work was done that you got paid for. In addition, they will deduct any wages you were paid for days you actually did not work such as sick leave pay or vacation pay. SSA considers many things in addition to the amount you received in gross wages such as:
• The value of your work compared to non-disabled coworkers and whether you got help doing your job from an agency or your employer (Subsidy/Special Conditions);
• Whether or not you paid expenses related to your disability because you were working, (Impairment Related Work Expenses, Business expenses, unpaid help); and
• How long you were able to earn more than the SGA level and whether you were unable to keep earning SGA level wages beyond 6 months due to your disability (Unsuccessful Work Attempt or UWA).

Using Subsidy and Special Conditions: SSA is only interested in earnings that represent the real value of the work you perform. SSA understands that support may be provided by your employer that may result in you receiving more pay than the actual value of the services you perform. They call this “subsidy”. In addition, SSA realizes that you may receive support provided by someone other than your employer – for example, a vocational rehabilitation agency. As a result of this support, you may be receiving more pay than the actual value of the services you perform. They call this type of support “special conditions”. SSA will reduce the amount of income they count by the value of the subsidy and/or the special conditions you receive when deciding if your earnings are SGA.
Subsidies exist when employers pay workers more in wages than the reasonable value of the actual services performed. To qualify, individuals must have evidence of receiving subsidies such as extra support, supervision, or documentation of lower productivity compared to unimpaired workers performing the same or similar work.
In developing subsidies, employers are requested by the SSA to submit statements documenting the actual value of workers’ services. Subsidies may be either specific or non-specific. In specific subsidies, employers designate a specific dollar amount after calculating the reasonable value of workers’ services. In non-specific subsidies, employers are unable to designate a specific dollar amount as the subsidy. The amount of subsidies is determined by comparing the work of individuals in terms of time, skills, and responsibilities with that of nondisabled individuals in similar work. The proportional value of the work must then be estimated according to the prevailing pay scale of this work. SSA makes this determination.
The following list of possible indicators of subsidies is not exhaustive and questions regarding a specific example should be directed to the local SSA office.
• Sheltered employment;
• Childhood disability involved;
• Mental impairment involved;
• Marked discrepancy between amount of pay and value of services;
• Claimants or someone else alleges that claimants do not earn their pay;
• Nature and severity of impairment indicates that employees receive help from others in doing the work; and/or
• Government-sponsored job training or employment programs.
• Friendship or relationship to employer;

Other factors unrelated to the performance of the worker;
• Does the employer consider the work to be worth substantially less than the amount paid? If so, what are the reasons for this view?
• If the individual is still on the payroll despite unsatisfactory work, what is the employer’s reasons for retaining them?
• If the individual is no longer employed, what led to the termination of employment?

Some questions that might help to figure out if you are receiving support (subsidies) from your employer.
Employer-Provided Job Subsidies (check those that apply and provide cost to employer whenever possible)
• ____ Extra supervision ____ hours at ____ per hour for month(s) of ____ Allows extra time to perform duties (describe):
• ____ Allows lower productivity (describe):
• ____ Special accommodations (describe):
• ____ provides special transportation ___ miles per day or ____ hours per month at ____ per hour.
• ____ Adjusts work schedule (explain):
• ____ Adjusts duties (explain):
• ____ Wages paid above productivity (explain):
• ____ Other (describe):
• Documented cost of employer provided subsidies ________________________
• Special Arrangements/Accommodations: are these workers subject to the same duties, expectations, responsibilities, and potential for promotion as other workers doing similar jobs for this employer? ____ yes ____ no
• Are there any special arrangements in place to maintain the client’s worker in this job? ____ yes ____ no (If yes, explain) were these jobs “created” specifically for this employment situation or client? ____ yes ____ no
The information in this document is meant to help you understand this work incentive. Remember that the SSA and other agencies make decisions about your benefits. This document is meant to be a resource, not a decision about eligibility.
Reference
• SSA Red Book 2015
• edi.cornell.edu/publications/ssa
• vcu-ntc.org/resources/listContent.cfm/58/0

Work incentives Protecting Health Coverage for People with Disabilities

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By: Claudia Luna

Extended Medicare Coverage for Working People with Disabilities For beneficiaries receiving SSDI

As long as your disabling condition still meets our rules, you can keep your Medicare coverage for at least 8 ½ years after you return to work. (The 8 ½ years includes your nine month trial work Period)
Your Medicare hospital insurance (Part A) coverage is premium-free. Your Medicare medical insurance (Part B) coverage will also continue. You or a third party (if applicable) will continue to pay for Part B. If your Social Security Disability Insurance cash benefits stop due to your work, you or a third party (if applicable) will be billed every 3 months for your medical insurance premiums. If you are receiving cash benefits, your medical insurance premiums will be deducted monthly from your check.


Continued Medicaid Eligibility (Section 1619(B)) For beneficiaries receiving SSI

One of the biggest concerns SSI beneficiaries have about going to work is the possibility of losing Medicaid coverage. Section 1619(b) of the Social Security Act provides some protection for these beneficiaries. To qualify for continuing Medicaid coverage, a person must

  • Have been eligible for an SSI cash payment for at least 1 month;
  • Meet the disability requirement; 
  • Meet all other non-disability SSI requirements; 
  • Need Medicaid benefits to continue to work; and
  • Have gross earnings that are insufficient to replace SSI, Medicaid and publicly funded attendant care services.

This means that SSI beneficiaries who have earnings too high for a SSI cash payment may be eligible for Medicaid if they meet the above requirements. SSA uses a threshold amount to measure whether a person’s earnings are high enough to replace his/her SSI and Medicaid benefits. This threshold is based on the:

  • amount of earnings which would cause SSI cash payments to stop in the person’s State; and
  • Average Medicaid expenses in that State.

If a SSI beneficiary has gross earnings higher than the threshold amount for his/her State, SSA can figure an individual threshold amount if that person has:

  • Impairment-related work expenses; or
  • Blind work expenses; or
  • A plan to achieve self-support; or
  • Personal attendant whose fees are publicly funded; or
  • Medical expenses above the average State amount.

The state of Florida 2015 annual threshold amounts for disabled and blind beneficiaries is $30,594

If you are a SSI or SSDI beneficiary and needs an individualized analysis of your situation please contact the Community Work Incentives Coordinator or benefits Planner in your area. Please check the SSA Website for more details: http://choosework.net