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Benefits Analysis Services

Categorized In: Case Services - Planned Services

Approved Date: May 26, 2023

Owner: Carla Lasley

Clients who receive local, state, and/or federal benefits will be referred and authorized for Benefits Analysis Services (also called 'Benefits Services') in accordance with standard procedures.  These services provide vital information about how benefits will be affected by earnings so the client may make an informed choice about working, as well as training and support regarding work incentives, wage reporting, and other processes relevant to earnings and benefits.

Individuals receiving Social Security Disability Insurance (SSDI) or Supplemental Security Income (SSI) benefits will be informed they may be protected from Continuing Disability Reviews (CDR) when their Ticket to Work (TTW) is assigned to Nebraska VR under an approved Individualized Plan for Employment (IPE), and will receive support to unassign their TTW if it is assigned to another entity. 

At case closure, VR Benefits Orientation Specialist/VR Specialist will provide information and support for the client to assign their TTW to an Employment Network (EN) within 90 days of case closure. 

1)    Following Benefits Orientation, Benefits Orientation Specialist provides the client/authorized representative information about the choice of Benefits Service Providers available in the area.  (See Benefits Services Providers Form that lists Benefits Provider choices in each area of the State and is used to document client's declination of Benefits Services.)

2)    Benefits Orientation Specialist completes Referral Form for Benefits Assessment and obtains client/authorized representative's signature on applicable releases (see forms/applicable releases in Benefits Orientation Chapter.) Benefits Assessment is authorized for all clients whose local, state, and/or federal benefits may be affected by earned income.  This affords the client informed choice about earning income that will affect benefits and allows them to be prepared for any benefits changes that come with earning income. See below for special circumstances and how to document clients' declination of Benefits Services, if applicable.  

 3)    Copies of all referral documents are placed in the case file in accordance with Documentation Policy and local office practices.  

 4)    Benefits Orientation Specialist/VR Specialist receives Benefits Assessment report and reviews for use in developing Individualized Plan for Employment (IPE) with client/authorized representative, and others.
 
 5)    IPE is signed; Ticket to Work (TTW) action is taken, as needed, to ensure assignment of TTW to VR. See link to TTW policy in Process section, below. 
 
 6)   Benefits Planning is authorized.
 
 7)    Benefits Planning report [Benefits Summary and Analysis/Work Incentives Plan (BS & A/WIP)] is reviewed by Benefits Services provider in a meeting with client/authorized representative, VR Specialist, and others, as applicable.
      
 8)   VR Specialist/Benefits Orientation Specialist follows-along with client as needed to review income reporting requirements and tools for reporting, supporting client to establish regular and accurate reporting of earnings to Social Security Administration (SSA), Department of Health and Human Services (DHHS), and other sources of benefits, such as local Housing Authority.
 
 9)   Plan to Achieve Self-Sufficiency (PASS) is authorized if identified in BS & A/WIP, or if determined to be a viable work incentive after the BS & A/WIP is developed and prior to VR case closure.
 
 9)   Benefits Management is authorized when issues or concerns with benefits occur after Benefits Assessment and Benefits Planning are provided -- with a limit of two authorizations during the time the VR case is open.
 
10)  All benefits services reports are uploaded to QE2 to allow ease of access and case continuity.
 
11)  VR Specialist/Benefits Orientation Specialist follow-along with client as needed to continue review of income reporting requirements and tools for reporting, supporting client to establish regular and accurate reporting of earnings to Social Security Administration (SSA), Department of Health and Human Services (DHHS), and other sources of benefits, such as local Housing Authority. At case closure, VR Specialist supports the client, as needed, to assign their Ticket to Work per Successful Closure and Termination policies.   

Process for authorizing Benefits Assessment and Benefits Planning Services

1. Following Benefits Orientation, client is referred for Benefits Assessment, which is authorized for all clients who receive local, state, and/or federal benefits that may be affected by earning income.  Benefits Assessment is typically completed before the IPE (in Assessment) so the information gathered may be used to develop the IPE, to identify errors in the Social Security record, and to afford the client initial information to make an informed choice about earning income that affects benefits. Immediate referral for Benefits Assessment after the Benefits Orientation provides time for the Benefits Provider to complete the assessment while other career planning activities are completed so the IPE can be developed within the 90-day timeframe called for in regulation. 

2. The Benefits Services Providers Form attached to this chapter is reviewed with client who chooses a Benefits Provider from available options.  This Form is also used to document a client's declination of Benefits Services, as signed by the client and filed in the case file.  The form is filed with releases and consents in the case file.  (See below for details about declining Benefits Services.) 

3. Benefits Assessment referral and authorization is completed. Elements of the Benefits Assessment service include, but are not limited to:

  • Gathering of client's personal information for intake -- living situation, support system, possible work incentives, employment goals, past work history
  • Reviewing VR Benefits Orientation, checking for understanding and comprehension of information to build client's knowledge/understanding of possible work incentives
  • Requesting Benefits Planning Query (BPQY) for review (if applicable, as VR will forward copy if the one on file will be less than 90 days old at time Benefits Services are to be completed)
  • Verifying all benefits [Social Security Administration (SSA), Department of Health and Human Services (DHHS)--Economic Assistance (EA), Medicaid, and Division of Developmental Disabilities (DDD) Home and Community-Based Medicaid Waiver services, Housing subsidy, etc.]
  • Identifying current benefits issues pertaining, but not limited to:
    • Loss of Social Security benefits and understanding overpayments that are being collected 
    • Medicaid case suspension or closure, starting application process if no other supports are available
    • Incorrect information on BPQY or indication of not reporting wages 
    • Consideration of self-employment plan
  • Identifying and providing information on how to access community resources, as needed
  • Assisting with or identifying resources to assist with applying for additional benefits when such resources are not in place
  • Discussing that client's budget may need to be adjusted in light of earnings and benefits amounts changing and identifying services to help with budgeting if not already in place
  • Identifying methods and tools to report earnings

     For individuals who are already working, Benefits Assessment may be authorized to address issues such as, but not limited to:

  • Identifying actual work incentives available to the individual as they continue working
  • Identifying errors or red flags found in the BPQY record
  • Identifying work incentives not previously used or applied properly, including Student Earned Income Exclusion (SEIE), Impairment-Related Work Expenses (IRWE)
  • Identiying needed information andproviding instructions to correct local, state or federal benefits records errors, gaps in reporting income, or other unreported changes in the individual's circumstances (living arrangements, marital status, etc.)
  • Identifying and providing information on how to access community resources, as needed
  • Discussing that client's budget may need to be adjusted in light of earnings and benefits amounts changing, and identifying services to help with budgeting, if not already in place
  • Identifying current methods to report earnings and providing support to use other methods, as applicable 

     Consult with the selected Benefits Provider to identify whether a Benefits Assessment will provide optimal support for someone who is already working, or if authorization for Benefits Planning (following IPE development) will provide sufficient information for the client to make an informed choice about working and how benefits will be affected.      

4.  Authorize $345.00 for Benefits Assessment.  The service is entered as QE2 Category:  Career Planning, QE2 Service:  Benefits Assessment.          

5.  VR Benefits Orientation Specialist and VR Specialist, if not one and the same, receive and review Benefits Assessment report which includes:  types of assistance received, different levels of potential income with work incentives that are options at each level, health insurance/coverage (Medicare/Medicaid/employer/parent/spouse) and guidelines for continued coverage, as well as notations on how errors found in the SSA BPQY record were resolved, as applicable.  

6.   While the Benefits Assessment report has been reviewed with the client by the Benefits Services provider, additional review and discussion with the client in the context of development of the IPE will be completed by the VR Specialist.

7.  Review the client's Ticket to Work (TTW) status (determined at the time of the Benefits Orientation.) If the client's Ticket is currently assigned to another entity, provide support to unassign the TTW so it may be assigned to VR when the IPE is signed.  Follow process in Ticket to Work Chapter to unassign Ticket.

8.   After the IPE is signed, the Benefits Orientation Specialist/VR Specialist authorizes Benefits Planning. A determination about when to authorize this service (before or after job start) is made on a case-by-case basis.  Consultation with the Benefits Services Provider may help to identify the best time to authorize the service. People in circumstances such as the following may indicate a need to authorize before job start:

  • On SSI and needs calculation sheets to fully understand how earned income affects their payment to make employment choices
  • Receives Medicaid and working would put them over the Federal Poverty Level and they would qualify for Medicaid Insurance for Workers with Disabilities (MIWD)
  • Trial Work Period (TWP) months have been used and work incentives should be implemented immediately to try working without going over SGA right away
  • PASS is needed to meet the employment goal
  • There is some hesitancy in moving forward to secure employment due to uncertainty about how benefits will be affected, and more detailed information is needed to review with team and/or get team support.

This service includes, though is not limited to, the following core elements:

  • Review of Social Security Disability Benefits (Supplemental Security Income (SSI), Social Security Disability Insurance (SSDI), Childhood Disability Benefits (CDB), Disabled Adult Child (DAC), Disabled Widow(er) Benefits (DWB)
  • Review of other disability-related benefits (Medicaid, Medicare, Veterans Administration (VA), Railroad Retirement Benefits, Workers Compensation, Unemployment, State and Local benefits, such as Housing, Energy Assistance, Supplemental Nutrition Assistance Program (SNAP), etc.)
  • Identify benefits issues, record errors or inaccuracies in the benefits records
  • A summary of findings in a written Benefit Summary and Analysis/Work Incentives Plan (B S & A/WIP) using the Virginia Commonwealth University (VCU) standard reporting format
  • The delivery and review of BS & A and WIP at a meeting with required participants:  Client/authorized representative, if applicable, VR Specialist. Other participants may include Representative Payee, Developmental Disabilities Service Coordinator, Supported Employment service provider, etc.
  • Provide training on reporting earnings to client and those who provide their support, as needed 

8.   Authorize $690.00 for Benefits Planning.  The service is entered as QE2 Category: Benefits Counseling, QE2 Service: Benefits Planning.

9.   Payment for this service may be made after the BS & A/WIP review meeting is completed and the BS & A/ WIP and invoice are submitted to VR.

10. VR Specialist/Benefits Orientation Specialist review the earnings reporting requirements and tools for reporting when the person begins employment and provides reminders and assistance as needed to support accurate reporting.

Process for authorizing other types of Benefits Services

PASS (Plan to Achieve Self-Sufficiency) Development

1. When identified in the BS & A/WIP as a viable work incentive option, PASS Development may be authorized.  This service may also be requested later by the client, VR staff, or the Benefits Services provider when a client's circumstances change, and PASS is identified as a viable work incentive option.  Elements of the PASS Development service include, but are not limited to:

  • Assistance with/preparation of PASS Form 545
  • Submission of the PASS for approval
  • Provision of education and training to client on PASS monitoring, including progress reviews, collection of receipts and bank statements, management of monthly deposits into PASS-dedicated account, and state benefits coordination
  • Coordination and communication with the VR Specialist
  • On-going cmmunication with the SSA PASS Cadre

 2.  Authorize $915.00 for PASS Development. The service is entered in QE2 as Category: Benefits Counseling, QE2 Service: Benefits PASS Development.

 3.  Invoice for this service may be paid upon receipt of a copy of the PASS Plan and identification of training and on-going support activities to be arranged for and/or provided to the client.

     

Benefits Management

1.  Benefits Management may be authorized when unforeseen problems or other crises arise, or critical transition points are reached after the provision of Benefits Planning or PASS Development have been completed.  Some y issues or concerns present while Benefits Planning or PASS Development are in progress will be addressed under those authorizations without a separate Benefits Management authorization. Benefits Management may be authorized up to two times prior to VR case closure.  Elements of the Benefits Management service include, though are not limited to:

  • When there is a need:
    • For PASS monitoring due to disability-related impairments and/or lack of natural supports for monitoring/reporting up to 6 months
    • To access additional work incentives, address issues with federal, state, and/or local benefits (including VA benefits, SSA, Housing subsidy, SNAP, Medicaid for Workers with Disabilities (MIWD), etc.) or to institute the use of an ABLE (Achieving a Better Life Experience) account
    • To address specialized orientation, such as that needed for Self-Employment
    • To problem-solve circumstances such as:
      • Loss of/reduction in SSA benefits
      • Loss of Medicaid/Share of Cost (SOC) notification
      • Problems with PASS Plan use
      • Failure to report or inaccurate reporting of earnings
    • To address changes at critical transition points, including:
      • FOR SSI RECIPIENTS
        • Starting or ending employment
        • Changes in earned or unearned income
        • Reaching the Break-Even Point (BEP) with earned income
        • Transition to MIWD/1619(b) status
        • Changes in student status or attainment of age 22 for Student Earned Income Exclusion (SEIE)
        • Reaching insured status for Title II benefits (SSDI, CDB, DWB, Retirement Insurance Benefits [RIB])
        • Changes in living arrangement, marital status, or resources
      • FOR TITLE II BENEFICIARIES
        • Completion of the Trial Work Period (TWP)
        • Beginning and end of the Extended Period of Eligibility (EPE)
        • Identification and use of Impairment-Related Work Expense (IRWE), Subsidy, or Un-incurred Business Expenses and Unpaid Help (if self-employed)
        • Substantial Gainful Activity Determinations
        • Beginning and end of Extended Period of Medicare Coverage
        • Attainment of dual entitlement (Childhood Disability Beneficiary [CDB] becomes insured on own record)
        • Transition to retirement benefits (early or full retirement age)
      • FOR DUAL ELIGIBLES (SSI and TITLE II)
        • Cessation of benefits due to medical improvement
        • Expedited Reinstatement of eligibility 
        • Overpayments or underpayments

 2.  Authorize $460.00 for Benefits Management.  The service is entered in QE2 as Category: Benefits Counseling, QE2 Service: Benefits Management.

 3.  Invoice for this service may be paid when a written report is submitted and identifies how issues were resolved.

NOTE ABOUT DECLINING BENEFITS SERVICES FOLLOWING BENEFITS ORIENTATION:

As noted in the Benefits Orientation Chapter:  During the Benefits Orientation, discussion of the importance of receiving Benefits Services is vital. A client who does not understand work incentives may be limiting their ability to maximize income and benefits to reach greater economic self-sufficiency.  The Benefits Orientation Specialist and VR Specialist (if not one and the same) play a key role in educating clients on the importance of accessing Benefits Services.  To ensure a client/authorized representative can make an informed choice about receiving Benefits Services, the VR Specialist will discuss the following:

Benefits Services, among other things:

1) Identify work incentives and other tools so that needed benefits are retained while maximizing earnings

2) Provide basic support for budgeting earnings and income

3) Address concerns with Social Security records found to be incorrect or incomplete

4) Provide training and information on how employment and earnings changes (such as starting or ending a job, or obtaining additional or different benefits) may signal the need to seek additional benefits consultation and support; and,

5) Provide continuity of support for benefits via Ticket to Work reassignment after VR case closure. 

If, given all this information, the client declines Benefits Services referral, the client's signature on the Benefits Services Providers Form will document such declination. At this time, the client will be informed they may request benefits services at any time while their VR case is open.

The Form documents the provision of informed choice and is filed in the client record with other consents/releases.  The declination will also be documented in a Customized Task note, titled, "Benefits Services Declined."  The note will include the reasons why the person refused the service after being provided information sufficient for them to make a choice to decline the service(s) and will document the client has been informed they may request benefits services at any time while their VR case is open. 

 


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