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

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106• Most <strong>of</strong> <strong>the</strong> agreements require <strong>the</strong> EN <strong>to</strong> reimburse <strong>the</strong> SVRA only for <strong>the</strong>costs <strong>of</strong> services provided. However, five agreements entitle <strong>the</strong> SVRA <strong>to</strong> ashare <strong>of</strong> <strong>the</strong> EN’s payments even after <strong>the</strong> SVRA has been completelyreimbursed for its expenditures.SVRA Incentive Payments. For <strong>Ticket</strong>s assigned <strong>to</strong> an SVRA, a small number <strong>of</strong>agreements define situations in which <strong>the</strong> SVRA will make “incentive payments” <strong>to</strong> a partnerEN for support services provided <strong>to</strong> help a beneficiary successfully maintain earnings aboveSGA. Five <strong>of</strong> <strong>the</strong> 27 SVRA-EN agreements identify some type <strong>of</strong> incentive payment,generally in <strong>the</strong> form <strong>of</strong> a lump-sum payment <strong>to</strong> <strong>the</strong> EN for services such as ongoingsupport <strong>to</strong> employed beneficiaries.Payment Sharing. Just three agreements call for an SVRA and an EN <strong>to</strong> share SSApayments in cases where <strong>the</strong> <strong>Ticket</strong> has been assigned <strong>to</strong> <strong>the</strong> SVRA. The intent <strong>of</strong> <strong>the</strong>seagreements is <strong>to</strong> allow ENs <strong>to</strong> receive reimbursement beyond <strong>the</strong> direct cost <strong>of</strong> purchase <strong>of</strong>service agreements previously negotiated with <strong>the</strong> SVRA for specific services. Theseprovisions are intended <strong>to</strong> balance out <strong>the</strong> provisions in <strong>the</strong> SVRA-EN agreements underwhich <strong>the</strong> ENs pay <strong>the</strong> SVRA in situations where <strong>the</strong> EN holds <strong>the</strong> <strong>Ticket</strong> and reimburses<strong>the</strong> SVRA for services provided. The result is a reciprocal arrangement in which <strong>the</strong> SVRAshares its payments with ENs (instead <strong>of</strong> <strong>the</strong> one-way agreements typical <strong>of</strong> most states,whereby only <strong>the</strong> EN shares its payments with <strong>the</strong> SVRA). From <strong>the</strong> perspective <strong>of</strong> SVRAs,this procedure is designed <strong>to</strong> increase ENs’ willingness <strong>to</strong> serve SSA beneficiaries.2. RSA Guidance on Comparable BenefitsSeveral SVRAs have criticized RSA for not providing clear guidance related <strong>to</strong>comparable benefits. To date, RSA has not issued definitive written guidance on howSVRAs should address comparable benefits in <strong>the</strong>ir agreements with ENs. In early January2005, RSA began circulating a draft information memorandum for comment. However, as<strong>of</strong> this writing, RSA has not finalized and transmitted <strong>the</strong> memorandum, entitled “Principlesand Promising Practices for Effective Cooperative Agreements between State VocationalRehabilitation Agencies and Employment Networks under <strong>the</strong> <strong>Ticket</strong> <strong>to</strong> <strong>Work</strong> <strong>Program</strong>.”Presentations by RSA staff (Stafford 2004) indicate that <strong>the</strong> question <strong>of</strong> whe<strong>the</strong>r servicesprovided under TTW constitute a comparable benefit is something that must be consideredfor each beneficiary ra<strong>the</strong>r than solely on <strong>the</strong> basis <strong>of</strong> <strong>the</strong> service-related informationspecified in an EN’s application <strong>to</strong> SSA.3. Extent <strong>to</strong> Which SVRAs and ENs Jointly Serve Beneficiaries Under <strong>the</strong> Terms <strong>of</strong>SVRA AgreementsAlthough many SVRAs have drawn up agreements with ENs, many ENs in a state maynot have signed <strong>the</strong> documents. Moreover, <strong>the</strong> fact that SVRAs may have signedagreements with several ENs does not ensure that large numbers <strong>of</strong> beneficiaries are jointlyserved under <strong>the</strong> terms <strong>of</strong> <strong>the</strong> agreements. For example, among <strong>the</strong> eight SVRAs weinterviewed:VI: State Vocational Rehabilitation Agency Participation in <strong>Ticket</strong> <strong>to</strong> <strong>Work</strong>

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