Evaluation of the Ticket to Work Program, Implementation ...

104case, the counselor selects the outcome-only option. Staff had determined that$10,000 is the average cost reimbursement.• In Vermont, SVRA staff select the outcome-only system for beneficiaries whoare on DI, under age 55, and will likely require less than $10,000 in services. Inaddition, the agency attempts to clinically appraise the likelihood that theindividual is capable of working above the SGA for some period that willgenerate enough payments for the agency to recoup its service costs.• In Massachusetts, SVRA staff select the milestone-outcome payment system forclients served exclusively through state funds. The Massachusetts legislaturesupplements the SVRA’s federal case service monies with funds beyond therequired match. One official indicated that SSA could not reimburse the agencyfor these additional state funds because the traditional payment system appliesonly to cases served through federal/state matched monies.D. SVRA-EN RELATIONSHIPSIn our initial evaluation report, we made the point that, while TTW regulations alloweach EN to negotiate an individualized agreement with an SVRA, most SVRAs have simplydeveloped a standard agreement for use with all ENs. Furthermore, because SVRAs andRSA have interpreted TTW as a “comparable benefit,” 5 SVRAs have typically craftedagreements requiring ENs to reimburse them for most or all services provided by SVRAs toa beneficiary whose Ticket was assigned to an EN. If a resource is identified as acomparable benefit, the SVRA views that resource as a “first dollar” expenditure, meaningthat the comparable benefit funds (i.e., the Ticket) are applied first before accessing SVRAfunds. Unfortunately, in crafting SVRA-EN agreements, SVRAs have interpreted the notionof comparable benefit broadly. If an EN indicated that it could provide a specific service inits application to the PM, then that service was viewed as a comparable benefit for all Ticketholders, and the agreement required the EN to reimburse the SVRA for the service.Informal guidance from RSA (Stafford 2003) has directed SVRAs to apply the concept ofcomparable benefits at the level of the individual consumer. If a specific service matches aservice in an individual’s IPE and is available in a timely manner, then the service should beconsidered a comparable benefit. If the service is not in the individual’s IPE or not readilyavailable at the time the individual requires it, the service should not be considered acomparable benefit. The latter approach to interpreting comparable benefits would requireENs to reimburse SVRAs for services much less frequently.5 Comparable services and benefits are defined in the Rehabilitation Act of 1973 as amended by theWorkforce Investment Act of 1998 as follows: “(A) Services and benefits that are provided or paid for, inwhole or in part, by other Federal, State, or local public agencies, by health insurance, or by employee benefits;(B) Available to the individual at the time needed to ensure the progress of the individual toward achieving theemployment outcome in the individual’s individualized plan for employment; and (C) Commensurate to theservices that the individual would otherwise receive from the designated State vocational rehabilitation agency.”Section 101 (a) (8), 34 CFR Part 361.5.VI: State Vocational Rehabilitation Agency Participation in Ticket to Work