Unfortunately, many unemployed people with disabilities are not
aware of work incentives for which they qualify.  On the
DIMENET BBS (508-880-7340),I just discovered a guide to federal
work incentives that seeks to address this problem.  Although it
is apparently a few years old, the information and advice remain
essentially current.

Since the document is about 130K in size, I've put
"End of Document" at the bottom to indicate whether you received
it completely.  If not and you want it, let me know and I'll send
it on disk.

Jamal Mazrui
National Council on Disability
Email: 74444.1076@compuserve.com

----------

         The ACCESS Guide to the Federal Work Incentives
                         Second Edition

    The Center for Independent Living of North Florida, Inc.
     Sponsored by The Division of Vocational Rehabilitation,
          Department of Labor and Employment Security,
                        State of Florida

INTRODUCTION: WHAT ARE "WORK INCENTIVES?"
     Eight out of every ten able-bodied working-age Americans
have jobs, but only one out of every ten Americans with a
disability works. For decades, physical and attitudinal barriers
in the community and the workplace kept persons with disabilities
from seeking and finding jobs, but the Americans with
Disabilities Act has begun to remove these barriers. What are the
major obstacles keeping people with disabilities out of the
workforce now? We believe that the answer is that most persons
with disabilities who are out of the job market could be working
if there was more money to spend helping them to prepare for and
find work. It costs money to put people with disabilities in
jobs! They need adaptive devices, personal assistance to help
them with their activities of daily living, accessible
transportation and medical insurance that will accept them
without punishing them for being disabled. They also need the
same kinds of things that "temporarily able-bodied" persons need
to have when they enter the job market: training and education,
suitable housing, an appropriate wardrobe, etc. If the ADA has
opened up the job market for persons with disabilities, we have
to ask ourselves next where the money will come from to prepare
and equip them for the job market. 
     Until now, persons with disabilities who wanted to work
relied primarily on assistance from state Vocational
Rehabilitation agencies. State VR agencies are funded by the
Federal Government according to an 80/20 matching funds formula:
the Rehabilitation Services Administration of the Federal
Government puts up 80% of the costs of maintaining a state VR
agency, and the state itself puts up 20%. Additionally, some
funds from Federal and state educational and employment-program
budgets are also used to help persons with disabilities get ready
for work, insurance companies spend some money on vocational
services and some funds are raised from charitable sources, too.
However, if all the money spent directly on helping persons with
disabilities to get jobs were added up from all these sources, it
would come to less that $2.5 billion a year. There are about 10
million working-age persons with disabilities who are unemployed;
if we assumed that just half of them wanted to work, there would
be a mere $500 per person to spend on helping them prepare for
it. Most disabled people need more than $500 worth of help, but
where will the money come from? Despite the recent
reauthorization of the Rehabilitation Act, we can't expect that
Congress will appropriate substantially more money for VR
programs, and many states already cannot afford to put up their
matching funds. Will persons with disabilities who could work sit
frustrated on endless waiting lists for services while the golden
opportunities opened up by the ADA wither and fade?
Any person with a disability who receives benefits from the
Federal Government should know that the Federal Government makes
tens of million of dollars a year in other funding available for
persons who want to work, through Work Incentives systems. The
Federal Work Incentives are specific programs which exist
specifically to help you make the transition from receiving
benefits to full- or part-time employment. There are Work
Incentives programs within the Social Security Administration,
the Department of Veterans' Affairs, the Internal Revenue Service
and the Department of Health and Human Services. If you receive
Federal benefits through any of these programs, the Work
Incentives will help you keep part or all of the benefits you
depend on for your survival and independence; you can also take
tax deductions to cover your costs-of-working. In some cases,
Work Incentives will increase the size of the benefits you
receive. If you use them properly, the Work Incentives will
eliminate many of the financial barriers that are keeping you out
of the job market.
     The Work Incentives can do six things for you: 1) they
provide you with the security of knowing that your benefits have
not been cut off, in case your new employment should not work
out; 2) they provide for your work-related expenses; 3) they
provide you with enough money to live independently until your
salary is high enough to cover your living expenses; 4) they
provide permanent subsidies for those who need them; 5) they
allow you to write work-related expenses off your taxes; and 6)
they provide you with a medical insurance plan that will cover
your disability-related health care needs, unlike many private
insurers.
     The Work Incentives can make you "your own vocational rehab
counselor," since they allow you to claim thousands of dollars in
benefits that you can use to develop your own employment plan.
You can also use the Work Incentives to "shelter" money or
property that would make you ineligible for Social Security
benefits. The Work Incentives can replace Vocational
Rehabilitation benefits that end when you become employed. In
theory, at least, the Work Incentives are designed broadly enough
to allow you to bring all your creativity to bear when you solve
the problems that are keeping you out of the workforce. The Work
Incentive policies even promote self-employment and
entrepreneurship.
     The philosophy of the Work Incentives is that if you can
earn part or all of your living, it is in the best interests of
our society to support you, even if you have to continue to
receive part or all of your benefits to subsidize your
employment. People who use the Work Incentives go from being
benefits-recipients to wage-earners and taxpayers, returning back
to the government some or all of what they received. 
Does this all sound too good to be true? Are you thinking, "If
such wonderful benefits exist, how come I've never heard of
anybody using them, and why are so many people with disabilities
still unemployed?" These are good questions! There are several
reasons why the Work Incentives system is underused. First of
all, the Work Incentives are complicated; more complicated, in
fact, than they need to be. Second of all, the Social Security
Administration, which operates most of the Work Incentive
programs, does not do very much to promote them or notify people
that they are eligible for Work Incentives. In fact, many
employees at Social Security Administration local offices have
never been trained to evaluate Work Incentive plans, and they may
never even have heard of some of the less frequently-used Work
Incentives. (This is very common in SSA offices that are located
in small cities and towns.) As a result, the employees of
Vocational Rehabilitation agencies, Associations for Retarded
Citizens, Goodwills, Easter Seals, rehab hospitals, Workers
Compensation counselors and even Centers for Independent Living
don't have access to reliable information about the Work
Incentives, and they don't inform their consumers about the Work
Incentives. A consumer who wants to use the Work Incentives needs
to find out all about them on his or her own before he or she can
file a Work Incentives  plan. 
     When the Center for Independent Living of North Florida
published a series of articles on the Work Incentives in ACCESS,
our newsletter, we received over 1110 requests for information
from around the country. Clearly, persons with disabilities want
to work and they want to use the Work Incentives. They just need
more information about the Work Incentives so that they can
become informed consumers and claim the specific Work Incentives
benefits they need.


WORK INCENTIVES OF THE SOCIAL SECURITY ADMINISTRATION

SOCIAL SECURITY BENEFITS: 
A  QUICK OVERVIEW
     There are 14 Work Incentives that persons who receive Social
Security Administration benefits can use. These are the most
widely used, the most flexible and the most generous Work
Incentives available. To understand them, you first need to know
a little about how Social Security works.
Persons with disabilities can receive two kinds of Social
Security: Social Security Disability Insurance and Supplemental
Security Income. Some persons receive both. Most Social Security
Work Incentives apply to one type of Social Security or the
other, but three Work Incentives apply to both programs.
Social Security Disability Insurance (SSDI) is a pension program,
based on Federal Insurance Corporation Act taxes you paid the
government during your working years. These pension taxes, known
as FICA for short, would have been the basis for your retirement
benefits if you had worked until retirement age. The size of your
SSDI benefits is based on the amount you paid into FICA during
the 40 "quarters" (three-month periods, or quarters of a year) of
your last ten working years. 
     SSDI is not "welfare." It is a pension plan based on a
"contract" between you and the Federal Government. The Federal
Government collects FICA taxes from you with the understanding
that you will get these funds back in the form of Social Security
benefits when you retire or become unable to work any longer.
Since SSDI is a pension rather than a form of welfare, you are
not required to sell any of your property and/or run through your
savings before you can receive your SSDI.
Supplemental Security Income (SSI) is an income support paid to
people who became disabled before they had a substantial work
history. If you are disabled and your total income from all
sources is below the Federal Guaranteed Minimum Rate, you will be
eligible for SSI. (In August of 1993 the Federal Guaranteed
Minimum Rate was $434 per month for singles, and $652.) Many
people who receive SSI have been disabled since birth or
childhood, and have never worked. Part of your SSI benefits are
paid for by the state in which you live; therefore, the Federal
Government allows states to decide if they wish to extend SSI
benefits above the Federal Guaranteed Minimum Rate, and the sizes
of SSI payments vary from state to state.
     The SSI program places a limit on the value of savings you
can possess and property you can own, so a few of the SSI Work
Incentives are designed to help you keep savings or property that
exceed the usual levels. SSI also has a number of Work Incentives
geared toward the needs of people who work in sheltered workshops
and other institutional settings, since persons with
developmental disabilities usually receive SSI.
     There are two kinds of property you are always allowed to
keep when you receive SSI: your house and a vehicle (usually a
car or pickup truck). There are limits, however, to how valuable
these pieces of property can be. They vary from state to state.
If your house or car exceeds the value limit for the state you
live in, you may (probably will) be compelled to sell it and buy
a cheaper one. After you have used up the difference between the
selling price of your property and the value limit for your
state, you are eligible for SSI. This issue sometimes arises when
a dependent child inherits a house or vehicle from his or her
parents. If the house, for example, is assessed at a value higher
than the value limit in the state where the child lives, he or
she could be required to sell it, buy a cheaper house and run
through whatever part of the proceeds of the sale are left,
before he or she can receive SSI again.
     If you worked briefly before becoming disabled, you could be
receiving both SSDI and SSI. Your SSDI benefits would be based on
your FICA payments during the last 40 quarters you worked, while
the SSI benefits would bring your monthly income up to the
Federal Guaranteed Minimum Rate. If you worked fewer than 40
quarters, your SSDI would be based on those quarters you did
work.
     Other benefits you might receive, such as Medicare and
Medicaid, are tied to your Social Security eligibility, so there
are Work Incentives that cover these benefits, too. 

BEFORE YOU GET STARTED
     Start planning how you will use the Social Security
Administration's Work Incentives long before you are ready to
look for a job. Your first step should be to get a copy of the
Social Security Administration's Red Book On Work Incentives,
also known as "SSA Publication No. 64-030". The Red Book, which
is free, is the definitive guide to the Social Security Work
Incentives, but it suffers from one major shortcoming: while it
lists and explains all the different Work Incentives in great
detail, it does not explain the application processes for any of
them. (If it did, you wouldn't need this Guide!) You can get a
copy of the Red Book mailed to you from your local Social
Security Administration Field Office, or your SSA Regional
Office.
     We said above that the Social Security Administration does
not always provide people with disabilities with accurate
information about SSA programs and benefits, especially the Work
Incentives. Several people who read the series of articles on
which this Guide is based reported to us that they were told by
SSA staff that the Red Book is not for distribution to the
public. Needless to say, the Red Book is for public distribution.
If an SSA staff member refuses to send you a Red Book for any
reason, you can contact your Social Security Administration
Regional Office and do two things: 1) file a complaint; 2) demand
your Red Book! A list of Social Security Administration Regional
Offices appears at the end of this Guide.
     Once you've gone over the Red Book and determined which Work
Incentives you are eligible for, write to your local Social
Security Administration office and explain to the staff that you
will be going to work soon and applying for certain Work
Incentives. (List them.) Ask to meet with the SSA staff member
who handles Work Incentives in that office. (Each SSA office has
a designated contact person for Work Incentives inquiries, plans
and reviews.) Explain to that person what you plan to do and ask
for his or her help. Many Work Incentives benefits cannot be
applied for after you return to work, so be sure to do this when
you start your job search.
     We are sad to report that there are not enough Social
Security Administration employees who are well-trained in the
Work Incentives. You must be as knowledgeable as you can be going
into the application process, and be willing to appeal your case
up the hierarchy if you don't get what you want at first. You
have the right to ask for any decision by the SSA to be
reconsidered. If you lose on the reconsideration, you may ask for
a hearing before the Administrative Law Judge (ALJ). It is a
known fact that the ALJ is more likely to give you what you want
and deserve than anybody else in the SSA -- if you have the
persistence and stamina to take your case to a hearing. (Roughly
2/3s of those who apply for SSI benefits are rejected at their
first application, for example; yet 2/3s of the applicants who
appeal their case all the way to the ALJ are awarded their SSI.)
If by some chance the ALJ turns you down, too, then you may sue
the SSA. However, to do that you must find a lawyer. There aren't
many lawyers who specialize in Social Security cases, and only a
very small fraction of them are familiar with the Work
Incentives.
     As you study the Work Incentives and identify the ones that
will help you, you may wish to inquire at your local vocational
rehabilitation office or Center for Independent Living to see if
they have any experts on the Work Incentives among their staffs,
in case you need help filing a Work Incentive plan or a local
advocate to help you straighten out a problem. Many Goodwill
agencies have experts in PASS, an SSI Work Incentive. 
Be aware that if you aren't willing to keep a few simple records,
you shouldn't bother to apply for Work Incentives. You need to
keep records on all your income and expenditures under your Work
Incentive plans. These records enable you to prove that you are
spending your Work Incentive benefits properly when your case is
reviewed. You should discuss record-keeping procedures with your
local SSA Field Office Work Incentives contact person and any
other experts whose help you seek. (We will have more to say on
records and reviews below. Trust us -- they're not so bad. We've
even included a few sample forms for you to copy and use, and
some sample "success stories" from persons who have used the Work
Incentives.)
     You may be one of those people who receives both SSI and
SSDI. If so, you can apply SSI Work Incentives to your SSI
benefits, SSDI Work Incentives to your SSDI benefits and the
SSI/SSDI Work Incentives to whichever benefits are most
appropriate. Many people take part in two or more Work Incentive
programs at the same time. (Of course, we understand that this
does get complicated!)

SSDI  WORK  INCENTIVES: ALLOWABLE INCOME
     If you receive SSDI, you may earn up to $500 a month without
losing a penny of your benefits, or $830 if you are blind. You
may do this for as long as you like. For most persons on SSDI,
this nearly doubles their income. That may be enough for them.
Others, who plan to return to full-time work eventually, can
build up years of valuable experience part-timing. The only
drawback to working part-time is that you may use up part or all
of your Trial Work Period (see below). 
The $500 figure ($810 for blind people) is a threshold. Above
that point, you have reached the "Substantial Gainful Activity
Level." Remember that phrase; it will come up again and again.
How To Apply: Notify your local Social Security Administration
Field Office that you plan to return to work part time. 
Records You Will Need To Keep: Copies of all your paychecks and
SSDI checks, and all your correspondence with the Social Security
Administration.
     A sample Income Log form appears at the end of this Guide.
You can use it to record all your income, from whatever source.

SSDI  WORK  INCENTIVES: TRIAL WORK PERIOD
     The first nine months after you begin working, you will
automatically receive your full benefits. This is your Trial Work
Period. If you are earning more than $500 (or $830 for a blind
person), you have crossed the line into the Substantial Gainful
Activity Level, and you will receive three months of further
benefits before they are reduced or cut off. These three months
are your Grace Period. The Trial Work Period and Grace Period
together are your "buffer zone;" they let you try yourself back
in the working world without any risks. If you cannot succeed in
working on your first attempt, you will not be punished for
failing and your benefits will not be interrupted. (If you are
working part-time and earning less than $200 a month, your Trial
Work Period and Grace Period do not begin; you have to earn more
than $200 to start your Trial Work Period.) 
     Your nine months of Trial Work Period do not have to be nine
continuous months. If you return to work, get sick, stop working
and then return to work later, your Trial Work Period picks right
up where you left off. The Trial Work Period is designed to
enforce the old adage, "if at first you don't succeed, try, try
again."
     Your Trial Work Period renews itself from time to time. The
number of Trial Work Period Months available to you is based on
the number of months you have used in the last sixty months. For
example, if you have used five months of Trial Work Period in the
last sixty months, you have four months available to you. You can
take several Trial Work Periods during the course of your career,
if you should need them, which benefits persons with progressive
impairments and persons who develop serious secondary
disabilities. This reform, known as the "rolling Trial Work
Period," was begun by Congress on January 1, 1992, and is one of
the newest of Work Incentives; as this is being written, it does
not yet appear in the Red Book.
     You can also get a fresh nine months of Trial Work Period
after you have been reentitled for SSDI. Reentitlement comes
about if you receive SSDI, leave the SSDI program after taking a
job, and then become eligible for SSDI after losing your job and
re-applying for SSDI. Should you then return to work, you will be
able to take a fresh Trial Work Period. (Reentitlement is not the
same thing as returning to SSDI during your Extended Period of
Eligibility; see the section on "Extended Period of Eligibility"
below to understand the difference.)
     With two checks coming in every month, the Trial Work Period
is also a good time for you to invest in yourself. Buy that new
wheelchair, modify your van, get a computer, do whatever you need
to do to insure that your new job is going to work out for you.
If you don't need to purchase anything right away, save the money
-- because you will eventually! 
     How To Apply: Notify your local SSA Field Office that you'll
be returning to work. If your benefits are cut off in error,
notify your local SSA Field Office immediately. 
     Records You Will Need To Keep: Copies of your monthly
paycheck and SSDI check, copies of any papers relating to your
dismissal (if you lose your job) and all of your correspondence
with the Social Security Administration.
     A sample Income Log form appears at the end of this Guide.
You can use it to record all your income, from whatever source.

SSDI WORK INCENTIVES: EXTENDED PERIOD OF ELIGIBILITY
     This is another "buffer zone" Work Incentive: if you lose
your job for any reason during the first 36 months after your
return to work, you can re-establish your eligibility for SSDI
without having to reapply for it. Your checks will start at once,
without the usual waiting period.
     The Extended Period of Eligibility is an extension of the
Trial Work Period "lifeline," to help you make the risky
transition to working without fears that your benefits will be
cut off irrevocably.
     The Extended Period of Eligibility begins the month after
your Trial Work Period ends. If you have to stop work for any
reason (such as a temporary medical difficulty), and you don't
earn enough in that month to exceed the Substantial Gainful
Activity Level, you can receive SSDI for that month. Your
Extended Period of Eligibility doesn't restart at that point,
however; it continues on until your 36 months are up.
     How To Apply: You should automatically receive your Extended
Period of Eligibility if you've gotten your Trial Work Period.
Notify your local SSA Field Office at once if you are forced to
stop working for any reason.  
     Records You Will Need To Keep: Copies of your monthly
paychecks, copies of any papers that relate to your dismissal (if
you lose your job) or leave of absence (if you have to take one),
and a copy of all your correspondence with the Social Security
Administration.

SSDI WORK INCENTIVES: CONTINUATION OF MEDICARE COVERAGE
     If you have Medicare, you will continue to receive it during
your Trial Work Period and Extended Period of Eligibility, and
for 3 months after the Extended Period of Eligibility: 51 months
altogether. The Continuation of Medicare Coverage Work Incentive
prevents you from losing your health care benefits suddenly,
which can be catastrophic for persons with disabilities who have
trouble finding private carriers to insure them. In this way it
acts as another "buffer zone" Work Incentive to allow you to
return to work without risking your "lifeline."
     How To Apply: You should automatically receive your
continuation of Medicare when you receive your Trial Work Period
and Extended Period of Eligibility. If your Medicare benefits are
cut off before your 51 months are over, notify your local SSA
Field Office immediately. 
     Records You Will Need to Keep: Copies of all your
correspondence with the Social Security Administration and the
Medicare authorities, as well as any medical bills that go unpaid
if your benefits are cut off in error.

SSDI WORK INCENTIVES: MEDICARE 4 PEOPLE W/DISABILITIES WHO WORK
     This is the most important of the SSDI Work Incentives, and
one of the newest. Although Congress created this Work Incentive
in 1990, many people -- including some SSA Field Office employees
-- have never heard of it.
     Essentially, this benefit allows you to "buy-into" Medicare
by paying a monthly premium, just as if you were purchasing
health care insurance from a private carrier. You don't have to
continue your Medicare by purchasing the premium; it's optional.
You'd just be foolish not to. If you choose to take part in
Medicare for People With Disabilities Who Work, your State
Government may pay the premium for hospitalization coverage
(Medicare Part A) and you will pay the premium for Supplemental
Medical Insurance (Medicare Part B). States that participate in
Medicare for People with Disabilities Who Work set an income
standard to decide who is eligible. To find out what that income
standard is, contact your local SSA Field Office.
You can only receive this Work Incentive if you've already had
the Continuation of Medicare Coverage Work Incentive. You must
apply for Medicare for People With Disabilities Who Work between
January 1 and March 1 of the year in which your Continuation of
Medicare Coverage will run out. You should automatically be
notified by mail that you have the option of applying. If you
think you may have been overlooked, you should contact your local
SSA Field Office well before March 1.
     You can continue to receive Medicare Coverage for Persons
with Disabilities Who Work for the rest of your working life,
until you reach age 65 and become eligible for the standard
Medicare program.
     This is an extremely important Work Incentive, because your
chances of buying private health insurance are low. If you try to
find coverage on your own, the chances are you won't be able to
afford it. If you join a group health coverage plan at your new
job, the chances are a "rider" will be attached to your insurance
that prevents you from getting treatment for any medical need
related to your disability. The "rider" may last for six months,
two years or forever. Since your biggest medical needs are
probably going to be related to your disability, a "rider" can be
disastrous. Medicare, fortunately, doesn't have "riders." (The
Americans with Disabilities Act prevents your employer's group
insurance plan from refusing to cover you, but the ADA does not
require the insurer to cover your disability-related medical
needs -- these so-called "pre-existing conditions" are still
subject to "riders.")
     Warning: When discussing Medicare for People with
Disabilities Who Work with SSA staff, be careful not to call it
the "Medicare buy-in." Although several disability-oriented
magazines have called it that, the term is used by the SSA to
refer to something else entirely, and you will cause considerable
confusion if you aren't careful.
     How To Apply: Fill in the form mailed to you; if you don't
receive one, contact your local Social Security Administration
Field Office well before March 1. 
     Records You Need To Keep: Copies of all your correspondence
with Medicare and the Social Security Administration.

A SPECIAL NOTE ON PASS FOR SSDI RECIPIENTS:
     Even if you don't receive SSI, check out the section below
on the Plan to Achieve Self-Support (PASS). PASS is intended for
people on SSI, but people on SSDI can use it too. Essentially,
you use all your SSDI funds to pay for work-related expenses, and
claim SSI to live on. (See the section entitled "A Note On the
'Left-Handed PASS,' below.)

SSI WORK INCENTIVES: EARNED INCOME EXCLUSION
     If you receive SSI, but also have unearned income (such as
benefits from a family trust), the SSA subtracts all but $20 of
that amount from your check. Earned income, such as wages and
salary, is treated differently. You get an Earned Income
Exclusion on wages and salary, so you can earn up to $500 a month
and still receive some benefits. The first $20 of your earned
income will be excluded under the "General Income Exclusion," and
the next $65 + 1/2 of the rest will be excluded under the "Earned
Income Exclusion." Your SSI benefits will then be reduced by the
amount of the remainder, known as your "Countable Income."
You can compute your "Earned Income Exclusion" this way: Subtract
$85 from your earned income. Now divide what's left in half. The
answer is the amount of your "Countable Income," and the amount
of your SSI will be reduced by this amount.
     An "income exclusion" is the size of your income that the
Social Security Administration does not count when computing the
amount of your benefits, not the amount of benefits you will
receive. Get used to the term "income exclusion," because many
Work Incentives are income exclusions. 
You can earn up to $500 ($830 if you are blind) and still receive
some SSI benefits. After your earned income exceeds $500, you may
be eligible to switch to a similar program, the Section 1619(A)
program. 
     How To Apply: The Social Security Administration should
automatically apply the Earned Income Exclusion to your benefits
when the IRS informs them that you are working. Contact your
local Social Security Field Office if your benefits are cut or
discontinued in error. 
     Records You Will Need To Keep: Copies of all your paychecks
and SSI checks, as well as all your correspondence with the
Social Security Administration.
     A sample Income Log form appears at the end of this Guide.
You can use it to record all your income, from whatever source.

SSI WORK INCENTIVES: STUDENT EARNED INCOME EXCLUSION
     If you are under 22 years of age, receive SSI and attend
college for at least 8 hours a week or a high school or work
training program at least 12 hours a week, you can use the
Student Earned Income Exclusion to earn up to $400 a month, for
up to $1,620 per year. (If shop practice is included in your
school curriculum, you must be in school 15 hours per week.) You
can use the Student Earned Income Exclusion even if you are
receiving homebound instruction because your health does not
permit you to attend school.
     Note: This Work Incentive is often used by developmentally
disabled youths in training programs, sheltered workshops or
other institutional employments settings. However, it is also
used to permit many other youths with disabilities to participate
in the Great American Coming-of-Age Ritual of after-school
part-time minimum-wage slavery.)
     How To Apply: Notify your local SSA Field Office by letter
before you start work. 
     Records You Will Need To Keep: Copies of school records that
verify your participation in a school or work training program,
as well as copies of all your paychecks and SSI checks, and all
correspondence with the Social Security Administration.
     A sample Income Log form appears at the end of this Guide.
You can use it to record all your income, from whatever source.

SSI WORK INCENTIVES: BLIND WORK EXPENSES
     If you receive SSI because you are blind, you can exclude
from your benefits all of your work-related expenses: guide dog
expenses, transportation to and from work, Federal, State and
Local Payroll taxes, FICA, personal assistance, visual and
sensory aids, translation of materials into braille or on tape or
disk, professional association fees, vision-related medical care,
union dues, adaptive equipment, computer expenses, etc. These
expenses do not have to be related to your blindness, just
necessary to work.
     The Blind Work Expenses Work Incentive comes on top of your
Earned Income Exclusion. Your Blind Work Expenses are taken out
first, and then your Earned Income Exclusion is computed. Most
visually-impaired persons on SSI who go to work will be eligible
for both, so be sure to apply for both, even if you think you
might not be eligible.
     You will need to estimate your monthly work expenses before
you can file your application. Annual work expenses (fees you pay
once a year) are figured into your estimate by dividing them by
12. Quarterly work expenses are figured into your estimate by
dividing them by three, etc.
     If you are over 65, you must have begun to receive SSI for
your blindness before you turned 65.
     How To Apply: Notify your local Social Security
Administration Field Office in writing before you begin work, and
include the estimate of your monthly employment-related expenses,
along with copies of any documents that support your estimate,
such as receipts or invoices. 
     Records You Will Need To Keep: Dated receipts of all your
work-related expenses in chronological order, along with an
itemized list with monthly totals. Also, keep copies of all your
SSI checks, paychecks and correspondence with the Social Security
Administration. As always, it is good idea to pay for all your
work expenses by check from a single account, to build up a
proper "paper trail." Record the check number for each work
expense you pay for by check.
     Sample forms for estimating your Blind Work Expenses and
recording them appear at the end of this Guide. A sample Income
Log form appears at the end of this Guide. You can use it to
record all your income, from whatever source.

SSI WORK INCENTIVES: PLAN FOR ACHIEVING SELF-SUPPORT (PASS)
     The Plan to Achieve Self-Support Work Incentive, known as
"PASS" for short, helps you keep income that would otherwise
disqualify you from receiving SSI. This income can be earned or
unearned, as long as you set it aside for the purpose of helping
you find and keep a job. PASS is frequently used to help you keep
Worker's Compensation benefits, insurance benefits, the
settlement from a lawsuit, etc. You can also use PASS to help you
save money given to you by your family, including an inheritance.
You can even file a PASS when you apply for SSI, to help you keep
savings that would otherwise make you ineligible -- as long as
you use the money to help you find and keep a job.
     Under some circumstances, the Social Security Administration
will increase the size of your monthly check, up to 100% more
than what you currently receive. You simply file a PASS plan that
devotes part or all of your SSI check for PASS expenses and then
you have, technically, little or no income, and the SSA will
raise the size of your SSI check to the back up to current level
of the Federal Benefit Rate. (In 1993, this is $434 per month.)
Therefore, you can draw up to $434 per month from the SSA for
your PASS program.
     A PASS consists of a written plan that lists the steps you
will take to prepare for work, the amount of money you'll need,
the expenses you'll have to cover, the source or sources of the
income you'll use for your PASS and a timetable that shows when
you'll complete every phase of the PASS and become ready for
work. Your PASS plan must be approved by your local Social
Security Administration Field Office, and is subject to periodic
reviews (see the section on REVIEWS, below). 
     Your PASS plan can include expenses for tools, adaptive
equipment, tuition, personal care, vehicle modification, special
work-related medical expenses, etc. (Transportation to and from
work isn't usually approved.) Congress has instructed the SSA to
interpret the PASS guidelines broadly, so that as many people as
possible may be covered by PASS. 
     The Social Security Administration suggests that you obtain
outside help to prepare a PASS plan and fill out the forms, since
you will be required to prove that you are capable of performing
the work you plan to do, and that your plan to start work is
reasonable. You may wish to consult your local vocational
rehabilitation office, Goodwill agency or Independent Living
Center, but this is not required. 
     PASS plans may cover up to three years of activities, and
can be extended for one additional year. A PASS plan can be
amended to reflect changing circumstances.

A NOTE ON "THE LEFT-HANDED PASS"
     PASS is intended mainly for persons who receive SSI, but it
is open to persons who receive SSDI, through a procedure
informally known as "The Left-Handed PASS." You simply draw up a
PASS plan that uses 100% of your SSDI check for PASS expenses,
and then you have, technically, "no income" and are entitled to
draw SSI benefits to live on. Although this is rarely done, it is
authorized at the highest levels of the SSA.
     PASS is very flexible! 

ADDITIONAL PASS RESOURCES
     There are some additional authorities on PASS you may wish
to consult. WORKING WHILE DISABLED (SSA Pub. #) is the Social
Security Administration's guide to PASS in all its varieties, and
includes a copy of the standard application form for PASS. It is
free from your local or Regional SSA Field Office.
David Scarborough, and outside expert, wise hired by the SSA to
write WORKING WHILE DISABLED,. He also has produced an
instructional video on PASS. He can be reached at (817) 861-5283,
or PO Box 202205, Arlington TX 76006. 
     Mr. Harry Hall of The Development Team has one of the best,
if not the best, record of helping persons with disabilities get
jobs. The Development Team can be reached at (410) 563-2170, or
1615 Thames St. Suite 300, Baltimore MD 21231.
     Many Goodwills around the country are now helping consumers
to write PASS plans as part of a national campaign to increase
the use of PASS. Check the Goodwill in your area to see if it
offers this service yet. (If it doesn't, try to get the staff
interested!)
     How To Apply: PASS is one of the few SSA Work Incentives
with a formal application procedure. Request a PASS plan form
from your local Social Security Administration Field Office.
Remember, you may apply for a PASS at the same time you apply for
SSI, to shelter income that would otherwise make you ineligible
for SSI. 
     Records You Will Need To Keep: 1) your written PASS plan,
with all amendments; 2) all receipts, invoices, paychecks, SSI
checks, bank statements and other financial records that are a
part of you PASS plan, filed in chronological order; 3) monthly
income and expense records; 4) a month-by-month narrative of your
progress toward completing your PASS plan; and 5) a complete
record of your correspondence with the Social Security
Administration. The narrative of your progress need not be
complex; a couple of paragraphs listing your PASS activities for
the month will do it. It could be as simple as a list of places
you applied for work, or a statement that you attended all your
classes during the month.
     At the end, of this Guide you will find a sample PASS forms,
for you to plan and keep track of expenses paid under your PASS
plan. We recommend that you pay all your expenses by check, from
a single account, to develop a proper paper trail. Always record
the check number each time you enter a PASS expense into your
log. 
     A sample Income Log appears at the end of this Guide. You
can use it to record all your income, from whatever source.
 
SSI WORK INCENTIVES: PROPERTY ESSENTIAL TO SELF-SUPPORT (PESS)
     The Property Essential to Self-Support Work Incentive allows
you to keep property you own (or may acquire, such as through an  
inheritance) which is essential to a job or business in which you
earn your living. All tangible goods, such as tools and vehicles,
are covered completely. You dwelling place and vehicle are
covered, too, subject to the restrictions on their value we
described above in the "Overview of SSI" section. Land on which
you operate a business or raise crops for sale or your own
consumption is also covered completely. (PESS is the last U.S.
Government program that promotes family subsistence farming!) Up
to $6,000 of equity in a non-business property needed for your
self-support is also included.
     If you do not have a PESS, the Social Security
Administration will require you to sell all your property
(including real property other than your dwelling place) and
spend all the proceeds in excess of $2,000. After you are down to
$2,000 you'll be eligible for SSI. A PESS, then, is something you
are most likely to file for when you apply for SSI, to establish
your eligibility to keep property SSA would otherwise make you
get rid of. You will also need to file a PESS when you inherit or
otherwise acquire valuable property you need to keep for your
self-support.
     A PESS may include tools, a computer, equipment for setting
up retail sales, office furniture, adaptive devices other than
durable medical equipment, etc.
     How To Apply: If you are applying for a PESS at the same
time as you're applying for SSI, attach your PESS to your SSI
application forms. If you're filing a PESS to allow you to keep
property you acquire after you receive SSI, notify your local SSI
Field Office by letter as soon as you acquire the property. Your
PESS plan consists of a detailed inventory of the property in
your PESS and a narrative statement that explains how you will
use it for self-support, with an estimate of the income you
expect to receive. 
     Records You Must Keep: A copy of your PESS plan and any
amendments to it, a monthly chronological accounting of all
income and other benefits you received from your PESS, a
chronological record of all receipts and other financial records
related to your PESS and copies of all your correspondence with
the Social Security Administration.

SSI WORK INCENTIVES: SECTION 1619(A): 
Special SSI Payments for People Who Work
     Once you pass the Substantial Gainful Activity Level of $500
(or $810 if you are blind), you may still receive SSI by
excluding some of your work income. (Remember, "an income
exclusion" consists of the income SSA does not count when
computing how much you will receive in benefits, not the amount
you will receive in benefits.) The SSA will calculate your
exclusion in the same way that Earned Income Exclusions and
Student Earned Income Exclusions are calculated (see above).
First, SSA will exclude the first $20 of income under the general
exclusion, and the next $65 of earned income under the Earned
Income Exclusion. Next, SSA will exclude half of the rest of your
earned income up to $500. The total earned income that can be
excluded under Section 1619(A): is $385. That's $20 + $65 + 1/2
of $500.) If your earned income falls under $500 after the
exclusions, you can receive some SSI benefits. The amount you
receive will vary from state to state. 
     As if it weren't already complex enough, Section 1619(A):
can be used in conjunction with PASS or the Impairment-Related
Work Expenses (see below). If you have monthly employment
expenses covered by PASS or IRWE, you take them off the top, and
then apply the Section 1619(A): exclusions.
     How To Apply: Before your monthly income reaches the point
where it would exceed the $500/$830 threshold, notify your local
SSA office by letter that you plan to use a Section 1619(A): Work
Incentive. The letter should include your calculations proving
your eligibility. Your application will probably come after you
have used the Earned Income Exclusion and/or the Student Earned
Income Exclusion for a while, so the SSA Field Office will be
familiar with your case.
     Records You Will Need To Keep: Copies of your paychecks, SSI
checks and correspondence with the Social Security
Administration.
     A sample Income Log form appears at the end of this Guide.
You can use it to record all your income, from whatever source.

SSI WORK INCENTIVES: SECTION 1619(b): 
Continued Medicaid Eligibility
     You may continue to receive Medicaid after you begin
working, even if you no longer receive SSI, as long as your
income falls below a threshold and you need Medicaid benefits to
enable you to work. The formula for calculating the threshold
differs from state to state, since Medicaid is a joint
Federal/state program, and state governments have considerable
say over what Medicaid benefits they will offer.
     This Work Incentive is particularly important in states
where Medicaid offers personal assistance services.
     How To Apply: Contact your local SSA Field Office and your
local Medicaid office before you begin working, to find out what
the income threshold is in your state. After you begin working,
contact your local SSA Field Office before your income rises
above the level at which you will stop receiving SSI. 
     Records You Will Need To Keep: Medical records that verify
you need Medicaid to continue working, verification of all your
medical expenses, copies of all your paychecks and SSA checks,
and all your correspondence with the Social Security
Administration.
     A sample Income Log can be found on at the end of this
Guide. You can use it to record all your income, from whatever
source.

SSI/SSDI WORK INCENTIVES: SUBSIDIES
     This Work Incentive is available to people who are receiving
SSI, SSDI or both.
     Subsidies are reasonable accommodations an employer makes to
enable a worker with a disability to hold a job when that
particular disabled worker cannot do the job as well as an
able-bodied worker. If a disabled worker is assigned fewer or
simpler tasks than an able-bodied worker would be assigned in the
same job, the difference between the value of their work is
called a Subsidy if they are both paid the same. If a disabled
worker has a job coach to supplement his or her work, the job
coach is considered a Subsidy if the disabled worker is paid the
same as an able-bodied worker.
     The Social Security Administration deducts the value of the
Subsidy from your earnings when they calculate whether you have
passed the Substantial Gainful Activity Level ($500 for non-blind
persons and $810 for blind people). Only the real value of your
work is considered when the SSA computes whether you have passed
the Substantial Gainful Activity Level. A Subsidy is not
subtracted from your countable income when they compute the size
of your SSI check. 
     A Subsidy could help you "phase-in" to a job you're not
quite ready for yet. The Subsidy Work Incentive is most
frequently used by people who work in supported employment,
sheltered workshops and other institutional employment programs.
     How To Apply: Discuss with your employer whether you will
receive a Subsidy. If you will receive a Subsidy, your employer
needs to contact your local SSA Field Office and inform the staff
member who is handling your case. 
     Records You Will Need To Keep: Your employer should be able
to document the existence of your Subsidy. You should keep a copy
of all his or her correspondence with the Social Security
Administration, as well as all your paychecks and Social Security
checks.

SSI/SSDI WORK INCENTIVES: 
SECTION 301 CONTINUED PAYMENT UNDER A VOCATIONAL REHAB PLAN
     If you should make a "medical recovery" and cease to be
disabled, you may continue to receive your SSDI or SSI checks for
a limited time while you complete your vocational rehabilitation
program, as long as you are already in a vocational
rehabilitation program when your medical recovery occurs. This
benefit is available to persons who receive SSI, SSDI or both.
A "medical recovery" is not necessarily a full recovery to your
pre-disabled state of health and fitness. In some cases, you can
achieve "medical recovery" if drugs control your disabling
symptoms enough to eliminate them as a barrier to work.
     This Work Incentive exists primarily because some vocational
rehabilitation services, such as surgery, frequently result in a
"medical recovery;" yet a consumer of vocational rehabilitation
services may need to continue in his or her program after the
surgery or other medical service is complete. 
     You don't have to be a client of your state Vocational
Rehabilitation agency. Any approved vocational rehabilitation
program is acceptable, such as a Worker's Compensation rehab
provider. If you aren't in a state VR agency program, contact
your local SSA Field Office to see if the program you are in is
approved.
     If you make a "medical recovery," the Social Security
Administration will decide whether you need to complete your VR
program to become self-supporting and independent. If they decide
that you need to finish, your benefits will be continued just as
if you remained disabled. 
     Anecdotal evidence and an informal survey suggest that this
particular Work Incentive is rarely used.
     How To Apply: When you or your physicians send in medical
records to document your "medical recovery," make sure that you
also include a letter informing your local Social Security Field
Office that you are in a vocational rehabilitation program and
wish to claim a Section 301 Continued Payment. The SSA will make
the decision in conjunction with your vocational rehabilitation
counselor. You may find yourself sending in your letter of
application after you receive a Notice of Review (see below under
"A WORD ABOUT REVIEWS" for more information about the Notice of
Review letter) informing you that you are considered "medically
recovered." We strongly suggest that you contact the SSA first,
before you reach "medical recovery," because otherwise SSA may
cancel your benefits first and ask questions later.
     Records You Will Need To Keep: A copy of all the medical
records sent to the Social Security Administration, and all your
correspondence with the SSA on this or any other matter.

SSI/SSDI WORK INCENTIVES: IMPAIRMENT-RELATED WORK EXPENSES
     We saved the best for last.
     The Impairment-Related Work Expenses (known as IRWE) are the
most flexible and enduring of all Social Security Work
Incentives. You can receive benefits through IRWE for your entire
working life. IRWE is the most commonly-used of all Social
Security Work Incentives.
     IRWE provides continuing SSI or SSDI benefits to offset the
unique expenses disabled workers have to carry in order to work.
IRWE enables you to start working at an entry-level salary and
continue to receive your benefits in order to pay for personal
care, medical costs, mobility aids, adaptive equipment and other
"impairment-related" costs.
     If you receive SSDI, the total amount of your IRWE expenses
are subtracted from your earnings, and only the remainder are
used to determine if you have passed the Substantial Gainful
Activity Level. If your job earnings minus your IRWE fall below
the Substantial Gainful Activity Level, you can receive your full
SSDI benefits for several years after you begin employment.
If you receive SSI, your IRWE expenses are still subtracted to
determine if you have passed the Substantial Gainful Activity
Level, but IRWE also works for you in a second way: your IRWE
becomes another income exclusion, one that is figured on top of
your Earned Income Exclusion.
     The expenses that go into your IRWE must meet three
criteria. First, you must be paying them instead of some third
party such as Medicare, Medicaid, vocational rehabilitation or
your employer. Second, they must be directly related to your
impairment, and not general work expenses. Third, they must
strictly work-related, and not general disability-related
expenses. 
     IRWE has a number of tricky loopholes, and the trickiest of
them concern IRWE and personal care. Personal care you receive
during workdays at home and on the job can be included under
IRWE. Personal care on weekends and holidays cannot be included
under IRWE. Veterans of IRWE suggest that you pay your personal
care assistant with separate checks: one for IRWE hours and one
for non-IRWE hours. Separate checks allow you to document
precisely which dollars went to IRWE-covered care and which ones
covered weekend and holiday care.
     Transportation expenses are handled differently. You can
deduct the entire cost of vehicle modifications, even if you plan
to use your vehicle for non-work purposes. The SSA also allows
you to include mileage to and from work at an approved rate.
(Check with your local SSA Field Office to determine which rate
applies to you.) Public transit expenses are only included under
IRWE if they are higher for riders with disabilities than the
public transit costs an able-bodied rider would pay. If your
local paratransit costs more than the mainline bus service, your
paratransit costs can be included. If there is no accessible
public transit where you live, cab fare can be included in your
IRWE.
     All medical devices, such as splints, dialysis equipment and
wheelchairs, are included under IRWE. (If you purchased them
through an insurance plan with co-payments, such as Medicare,
your co-payments are included under IRWE.) Your computer,
typewriter, TDD and other adaptive gear are also included under
IRWE if, and only if, you use them on the job and paid their
costs out of your own pocket. All disposable medical supplies
used on workdays are included under IRWE. 
     The routine medical care you require to manage your
disability can also go into your IRWE, including diagnostic
services, surgery, medication and physician's fees. No medical
expenses can be included under IRWE unless they are related to
the disability for which you receive Social Security benefits. 
Your local SSA Field Office may ask you to divide your total
medical expenses by the number of days in the year, and then
count only the portion of your medical care bills that cover the
number of days you work. (For example, if you work 20 days a
month, then you can figure on deducting 2/3s of your medical
expenses, because 240 = 2/3s of 365.) Some IRWE users report that
they had to list medical devices such as wheelchairs in the same
way. This is not legitimate. All your impairment-related medical
expenses and all of your durable medical equipment can be
included under IRWE. If an SSA employee expects you to comply
with these requirements, fight it.
     In choosing the benefits to be included in your IRWE and
filing the documents to support it, it is important for you to
remember that "grey areas" and "questionable items" can mean
trouble. If you're not sure than an item is something you can
include under your IRWE, check with the Work Incentives
Specialist at your local SSA Field Office or leave it out
altogether. Don't jeopardize a good IRWE by trying to push it too
far. The Red Book lists over 35 specific examples of included
expenses, so it's especially important to get a Red Book if
you're going to file an IRWE.
     Nonetheless, the "grey areas" and "questionable items" can
still get you in trouble. The comments we have received from
people who have been in contact with us about the Social Security
Work Incentives indicate that the list of allowable IRWE items
varies from one SSA Field Office to the next, and sometimes even
between two employees of the same SSA Field Office. You should
always be careful to get your IRWE rulings in writing, and never
depend on what you are told over the phone. Additionally, be
aware that some consumers have been told that SSA can legally sue
you or withhold benefits to reclaim money that was paid to you
under IRWE, even if your IRWE plan was approved, as long as
someone decides later on that your IRWE had mistakes in it.
However, and this is important, the Administrative Law Judge will
probably rule on your side if you have written proof (usually in
the form of a letter) that your IRWE plan and each expense in it
was approved by the SSA. In other words, the ALJ will hold the
Social Security Administration responsible for the error instead
of making you pay for it. (We don't want to discourage you from
using IRWE. We just want you to be careful.)
     How To Apply: When you notify your local SSA Field Office
that you plan to return to work, attach an itemized list of IRWE
expenses with the letter. Have receipts and other documentation
ready to verify any expenses the Work Incentives specialist might
question. 
     Records You Will Need To Keep: 1) a chronological file of
all receipts, invoices, canceled checks, paychecks, SSI and SSDI
checks and other financial records; 2) a complete chronological
log of all your benefits received and expenses paid under IRWE;
3) medical documentation establishing the need for any medical
services and/or medical and adaptive devices you use and 4) as
always, copies of all your correspondence with the Social
Security Administration. IRWE requires more recordkeeping that
any other Work Incentive, but IRWE's greater flexibility and
scope is worth it.
     We recommend that you always pay your IRWE expenses with
checks drawn on a single account, to create the proper "paper
trail." Always record the check number when you log in an IRWE
plan expense.
     Sample forms for estimating and recording IRWE expenses are
included at the end of this Guide. A sample Income Log form
appears at the end of this Guide. You can use it to record all
your income, from whatever source.

A NOTE ABOUT DEPRECIATION UNDER PASS AND IRWE
     One of the most useful things you can do in an IRWE plan
(which you can also do sometimes under PASS) is to set aside
money in a "depreciation account" just as if you were a big
business. "Depreciation," in this context, refers to your durable
medical equipment (wheelchairs, hospital beds, Hoyer lifts, etc.
and other adaptive devices (van lifts, specialized computer
keyboards, TDDs, etc.). All these things have an expected life,
and they will eventually wear out, or "depreciate," after which
time they must be replaced. Your IRWE (or PASS) can include money
paid into a special bank account in which you will save up to
replace your durable medical equipment and other adaptive
devices. You must careful, of course, to use this money only for
the purposes spelled out in your IRWE (or PASS). Spending this
money for other purposes may cause your IRWE (or PASS) to be
rejected, and you could then have to pay some benefits back to
the Social Security Administration.
     Here's how depreciation works: Begin by listing all of your
durable medical equipment and other adaptive devices, and
determine how many years the expected life of each piece will be.
Figure that you will provide normal maintenance, but that at some
point, it just won't make sense to keep fixing the item. This
period is your "depreciation schedule." (If you aren't sure how
long a given item should last, check whatever documentation came
with it. If you still aren't sure, call the manufacturer and ask.
You'd be surprised how honest some manufacturers are about the
planned obsolescence of their products. If it isn't practical for
you to call the manufacturer, just plan on seven years, which is
the depreciation schedule recognized by the U.S. Government for
many items.)
     Next, compute your "depreciation cost," which will be the
same as the present-day price you would pay to replace the item
if it died tomorrow, plus 15% for inflation. 
     Your annual depreciation for each item is the depreciation
cost divided by the depreciation schedule. Since PASS and IRWE
expenses have to be logged monthly, divide your annual
depreciation by twelve to get your monthly depreciation. The
monthly depreciation goes in your IRWE or PASS, and becomes part
of your income exclusion or PASS benefits. 
     Depreciation can add up fast. For example, if you are
simultaneously depreciating a van lift, powered wheelchair,
hospital bed, Hoyer lift, adaptive keyboard and electronic door
opener, you could be putting $500 a month in your depreciation
account.
     Social Security Administration employees may look at
depreciation as a "grey area" if they have never seen a
depreciation account built into an IRWE or PASS. Nonetheless,
depreciation is solidly established as a permissible expense
under IRWE and PASS. A depreciation account is your protection
against the high cost of adaptive devices, and your need to
replace them regularly. (Remember, once you are working, your
local state vocational rehabilitation agency may not be able or
willing to replace them for you.)
     A sample Depreciation Schedule form appears at the end of
this Guide. You can use it to compute your monthly depreciation,
and attach it to your PASS or IRWE.

STACKING
     Social Security Work Incentives are like potato chips . . .
most people can't take just one.
     Most people who use the Work Incentives "stack" them by
taking more than one at a time. In the case of the SSI Work
Incentives, "stacking" is explicitly encouraged by the rules that
define the order in which the income exclusions are to applied:
PASS, IRWE or the Blind Work Expenses first, and then the Earned
Income Exclusion or Student Earned Income Exclusion is applied to
the income left over. (If you are still above the Substantial
Gainful Activity Threshold, Section 1619(A) may permit you to
keep some of your SSI. SSI recipients also frequently use the
Property Essential to Self-Support (PESS) at the same time as the
other SSI Work Incentives.)
     Stacking is not "taking too much of a good thing." Each SSA
Work Incentive was designed to help you manage one specific
aspect of the transition from receiving benefits to working for a
living, and you should use every Work Incentive you are eligible
for. The Continuation of Medicare Work Incentive won't help you
with the high cost of van modification or paratransit; you need
IRWE for that. IRWE and the Earned Income Exclusion won't help
you with after your income rises high enough that your IRWE
doesn't lower it below the SSI Substantial Gainful Activity
Threshold; you need Section 1619(A) to help you keep your SSI
benefits.
     SSDI recipients who use the Work Incentives almost always
use all of them in a single plan: the Trial Work Period ends, and
the Extended Period of Eligibility automatically begins,
including the Continuation of Medicare; then the Medicare for
Persons with Disabilities Who Work picks up when Continuation of
Medicare ends. They usually add IRWE to the pot, as well.
Certain Work Incentives only kick in after you've been working
for a while, like Medicare for People with Disabilities Who Work.
You need an informal Master Plan for your working future, which
will specify which Work Incentives you will use, what purposes
you will use them for, and when you need to apply for them. The
Work Incentives specialist in your local SSA Field Office will be
glad to see it, since it will give him or her a chance to correct
any errors you might make in advance.
     Think of the SSA Work Incentives as individual pieces of a
puzzle; your task is to fit them together in the most productive
way possible to meet your individual needs. Study the three
sample stories that appear below to understand better how the SSA
Work Incentives fit together.

CASE EXAMPLES
     Jim worked for 22 years before becoming disabled by a C-5
spinal cord injury at age 42. Since he worked and paid FICA taxes
for many quarters, he has Medicare and SSDI benefits of $675 per
month. After three years of computer training provided through
his state VR agency, he is ready to take a job with a local bank.
He requires personal assistance for two hours twice a day, for
which he pays $6 an hour. His wheelchair cost $5000, and has
three more years of expected life; his van lift cost $75000 and
has four more years of expected life. Jim pays $125 per month for
disposable supplies and other impairment related medical
expenses.
     Jim received his full benefits and Medicare during his Trial
Work Period. His salary was $850 per month. During this time, he
and his employer determined that it would be necessary for him to
have a personal computer and modem at home, to enable him to work
on days when he could not physically come to the office. At the
end of his Trial Work Period, he filed an IRWE plan, listing
these expenses:

Personal Care: 
20 days per month X 4 hours X $6 = $480
Impairment-related medical care: $125
Wheelchair depreciation: $160
Van lift depreciation: $180
Payments on his PC and modem: $100

     His total IRWE was $1045, and his combined income from both
SSDI and his salary was $1500. Therefore, his earnings fell below
the Substantial Gainful Activity Threshold ($1500 - 1045 = $455;
the Substantial Gainful Activity threshold is currently $500 for
non-blind SSDI recipients), and he received his whole SSDI check
until a year later, when his second raise brought his salary up
to $1000 per month. However, after the raise, he encountered some
medical problems, and began paying an average of $300 per month
in Medicare co-payments for decubiti treatments. The new
impairment-related medical costs raised his IRWE to $1345, and he
filed a new IRWE plan, and began to receive SSDI benefits again,
since he was still in his Extended Period of Eligibility and his
earnings (minus his IRWE) had once again fallen below $500.
Because his employer's group plan refused to cover his
SCI-related medical needs, Jim chose to purchase Medicare
Coverage for Persons with Disabilities Who Work when it became
available to him. His state paid the Part A premium, and he paid
his Part B premium (which became an expense in his IRWE).
     Diana was born with cerebral palsy. At age 17, she began to
receive SSI payments of $434 per month, with Medicaid coverage.
She enrolled in college under the sponsorship of her state VR
agency. In her junior year, Diana took a job on campus working
part time as a research assistant, earning $300 per month. Her
parents gave her a personal computer to use in this work. She
filed a PESS (Property Essential to Self-Support) to be sure that
the value of the computer did not put her over the $2,000 of
property the SSI program allowed her to own. She also filed a
Student Earned Income Exclusion. Since the SEIE allowed her to
exclude up to $400 per month, she excluded all her part-time
wages for the first 5.5 months, until she reached the annual cap
of $1,660. She then filed an IRWE, to exclude $125 of monthly
expenses for disposable medical supplies not covered by Medicaid,
and an Earned Income Exclusion. Her exclusions came to $325 ($125
of IRWE, $20 of the General Income Exclusion and $180 of Earned
Income Exclusion). Therefore, she was found to have only $75 of
countable income, and her SSI was only reduced to $359, so that
her total income was $759.
     Upon graduation, Diana found work as a clerk-typist. She
earned $750 per month, but she filed a PASS plan to put the
entire amount in a bank account to save for graduate school
tuition. She therefore, technically, had "no income" and
continued to receive her full SSI. After 18 months of saving, she
entered graduate school, during which time she worked part-time
and used the Earned Income Exclusion to reduce the amount taken
from her SSI. (She was now too old for the Student Earned Income
Exclusion.) Upon completing graduate school, she took a job as a
counselor and filed for IRWE and Section 1619(A) to help her keep
her benefits, and Section 1619(B) to help her keep her Medicaid.
     Benny had three years of work experience before losing his
sight in an accident. He received only $100 per month of SSDI,
and was therefor eligible for SSI, as well. His SSI benefits were
reduced $80 ($100 - $20 of General Income Exclusion), and
therefore his total income was only $454. He received a
settlement of $15,000 from the accident, and filed a PASS plan to
keep it all in an account from which he paid for college and
adaptive devices. After college, he found a job as an actuary,
earning $1,200 per month. He filed a Blind Work Expenses plan to
exclude his payroll taxes, the costs of his paratransit, his
licensure and continuing education fees, his braille typewriter
and the cost of a reader. These came to $600 dollars a month, so
he continued to receive his full SSI, since $1200 of job earnings
minus $600 of Blind Work Expenses left him below the $830
Substantial Gainful Activity level for a blind person. For the
first 12 months of his employment (the Trial Work Period and
Grace Period), he also received his full SSDI.
     See how easy it all is?

UP POPS THE DEVIL: DEALING WITH PITFALLS
     The most commonly reported pitfalls in applying for and
using Work Incentives are 1) inadequately trained Social Security
Administration employees; 2) uncooperative Social Security
Administration employees, and 3) failure on the part of the
Social Security Administration to notify you that you are
eligible for benefits. If you read and save this Guide, you
should be well-informed enough to claim the benefits to which you
are entitled, so that problem is taken care of. Dealing with SSA
employees is another kettle of fish.
     Most SSA employees are not out to hurt you, or rule against
your Work Incentive plan just for the Hell of it. If somebody
rules against you on arbitrary grounds, or asks you to comply
with additional requirements that are not spelled out in the Red
Book, chances are that it was done out of ignorance, not malice.
SSA employees with little or no experience in Work Incentives
tend to make unnecessarily conservative judgements. As one SSA
employee put it, "Nobody pats you on the head for approving a
good Work Incentives plan, but you can be severely reprimanded if
you approve a bad one by mistake. Since we don't always have the
training and experience to evaluate Work Incentives plans, we
have to be careful." If you think you are in the right, just
stick to your guns. Everything should work out fine.
     It never helps you to return to work without notifying the
SSA. You won't get away with earning a paycheck and collecting
benefits, unless you are using the appropriate Work Incentives.
The SSA compares their records with those of the IRS every month
to spot people who have just been entered on the tax rolls.
Sooner, rather than later, they will catch you and try to recover
the benefits that were paid to you in error. You may find
yourself facing criminal fraud charges in very serious cases. As
troublesome and cumbersome as they are, you really must obey the
Work Incentives rules.

MORE ON RECORDKEEPING
     It isn't difficult or complex to keep the records you need
for your Work Incentive benefits. Don't let yourself be
intimidated by the notion of keeping records. As long as you are
consistent about keeping things organized and follow these simple
rules, you'll do fine. 
     First, never throw anything away. You need a chronological
"paper trail" to document your Work Incentive history. Keep all
your letters from the Social Security Administration, Medicare,
Medicaid, etc. Keep copies of your Social Security checks, the
stubs from your paychecks and copies of the checks you receive
from any other source of income.
     Second, use a checking account to pay all the bills covered
by your IRWE, Blind Work Expenses, or PASS. Your canceled checks,
along with invoices and receipts, will make up the paper trail of
your Work Incentive income and expenditures. If you are using
Work Incentive benefits to cover personal care, pay your
attendant with two checks: one for the hours covered by your Work
Incentives, and another for hours that are not covered. In fact,
this holds for any purchase you make: whenever you buy something
with your Work Incentive benefits, pay for it with a check that
covers only items paid for with your Work Incentives benefits.
     Third, keep all your Work Incentives papers in chronological
order. Buy a notebook and tape every piece of paperwork to a
page. Underneath each piece of paper, write in the date you
received it, along with any other information you might need
later to explain that particular expense or income. (As I've said
before, keep all of your correspondence with the Social Security
Administration, as well as all of your financial records.)
     Fourth, never send original paperwork anywhere in the mail.
Always keep your originals, and send only copies. This holds
especially true when you are mailing copies of your records to a
Social Security Field Office, where they receive literally tons
of mail a year.
     Fifth, keep a table of your income and a table of the
expenses you cover with your Work Incentives benefits. The table
of your income is very simple. Just list the date and amount of
all the income you receive, from any source. The table of your
Work Incentives expenses is not much more complex. You need to
record the date, the amount spent, who received the money and
what the money was for. (A sample Income Log appears at the end
of this Guide. You can use it to record all your income, from
whatever source.)
     Sixth, keep a chronological record of all your phone
contacts with the Social Security Administration: the date, time,
purpose of the call, any information you received or gave out and
the name of the person you spoke to.
     That's all you need!
     (Sample recordkeeping forms to get you started can be found
in the back of this Guide. These were developed by the Center to
give you an idea of what you need to do and ARE NOT officially
approved SSA documents, although they were reviewed by an SSA
Work Incentive Specialist, who found them helpful. Always discuss
recordkeeping procedures with the SSA Field Office staff person
who handles your Work Incentives, because he or she will set the
standard you'll have to meet.)

REVIEWS
     The Social Security Administration will review your case
every so often to determine if you are still eligible for the
benefits you receive. Usually, the frequency of your reviews will
be determined by the nature of your disability. If you have a
permanent, irreversible disability such as a spinal cord injury
you will be reviewed every seven years. If you have a disability
that might reasonably be expected to improve, such as cancer, you
will be reviewed every three years. If your application for
Social Security benefits contains a medical prognosis that
specifies a time after which you might no longer be disabled, you
will be reviewed at that time.
     If you enter a Work Incentive program, you will probably be
reviewed, and while you are in a Work Incentive program, you may
be reviewed more frequently than you were before you entered it.
Reviews are automatically triggered by certain changes in your
status. If you return to work, the IRS will inform the Social
Security Administration, and you'll automatically be reviewed. If
your status under the 1619 Work Incentives changes, you'll be
reviewed. You could also be reviewed if your local Social
Security Office "receives information" that your medical status
has changed.
     Reviews may be done by mail, face-to-face, over a phone or
by TDD. During a review you will be required to answer questions
put to you by Social Security Administration employees. You may
also be required to provide various documents, such as detailed
financial and medical records, and even to submit to a medical
exam to prove you are still disabled. (The Social Security
Administration will pay for it.) You need to be able to document
your income and disability-related expenses right down to the
penny. If you haven't kept the records, you can't expect to keep
your benefits.
     Anecdotal evidence suggests that reviews (sometime referred
to as "audits" by consumers and other people who are not SSA
employees) are frightening events for many people on Social
Security, especially persons in a Work Incentive program who have
not kept good records. The language in the Notice of Review
letter does seem ominous. However, an SSA review is not the same
thing as an IRS audit. The IRS audits you to prove that you've
done something wrong; the SSA reviews you to verify that you are
still eligible for the benefits you are receiving. 
     Two things can go wrong during a review. First, you may find
that Congress has changed the rules since your last review.
There's not much you can do about that, if it happens. Usually,
the Social Security Administration will not try to recover
benefits from you if they failed to correct your account when the
rules changed. You are more likely to come up against an
inadequately-trained SSA employee who is unfamiliar with your
case, and who throws out your Work Incentive plan because he or
she doesn't understand it. You may be able to resolve this type
of problem by taking your case to the reviewer's supervisor. If
that fails, you can appeal any changes in your benefits to the
Administrative Law Judge, who will almost always rule in your
favor. (The famous quad cartoonist John Callahan had his Work
Incentives program thrown out several times -- but he always got
it back.)
     Ninety-nine times out of a hundred, reviews will be no
problem, if you've kept your records in order.

REFORMS
     Despite its many useful features, we don't think the
existing Social Security Work Incentives system does a very good
job yet of serving persons with disabilities or the taxpaying
public. Only a few thousand people in the United States are able
to use the Social Security Work Incentives to improve their
employability and meet their independent living needs while they
make the transition into employment. Here are the numbers of
persons using the SSI Work Incentives, as of December 1992:

1619(A)        17,603
1619(B)        31,649
PASS            5,847
IRWE            7,813
Blind Work Ex.  4,454
TOTAL:         67,366

     There are millions of people, on the other hand, who could
benefit from the Work Incentives. In a very real sense, the Work
Incentives system is a good idea still waiting to be implemented.
Although the Work Incentives have steadily improved since the
1970's, when very few people could work and keep any Social
Security benefits at all, the Work Incentives systems still needs
some major reforms. Some of these reforms would have to come from
Congress, and would cost a lot of money. However, the most
important reforms could be made by the new Clinton Administration
with the proverbial "stroke of a pen," and Congressional approval
wouldn't be needed at all! (Nor would these reforms cost
anything.)
     The Social Security Administration could launch an internal
campaign to ensure that all SSA employees who deal with the Work
Incentives are well trained and take a positive and creative
approach to Work Incentive plans. SSA employees complain that an
assignment to handle Work Incentives is considered a dead end
within the SSA, a position from which future promotions are
unlikely. They also report that upper managers in the SSA are
unduly punitive when a Work Incentives plan with errors in it is
accidentally approved. The SSA higher-ups seem to be more
concerned about preventing the SSA from being ripped off than
they are about promoting employment, an attitude that has
trickled down from the SSA's political appointees in Washington
D.C. over the last 12 years. (No doubt many political appointees
within the SSA have also encouraged clumsy internal handling of
the Work Incentives to limit access to them as a misguided
cost-control measure.)
     Since few SSA employees are really knowledgeable about the
Work Incentives, and since the penalties for approving an
erroneous Work Incentives plan are so high, many SSA employees
tend to err on the side of caution and reject perfectly
legitimate Work Incentives plans, or cut off benefits to which
someone is still entitled. They do this, not out of malice
(although many persons with disabilities feel that they are
treated maliciously by the SSA), but because they don't care to
risk their careers on something they don't fully understand.
The Social Security Administration could write new rules
governing the way the Work Incentives are handled, taking a cue
from the new Rehabilitation Act. Until now, persons with
disabilities had to prove that they were capable of benefiting
from state Vocational Rehabilitation agency services; now they
are presumed to be employable and the burden of proof is on the
vocational rehabilitation agency to prove that they are not. The
SSA needs to change its rules so that people who want to use the
Work Incentives plan are "presumed eligible" to do so. The new
rules would state that if an IRWE or Blind Work Expenses plan is
rejected, the SSA is under an obligation to correct the faulty
plan. It would also be helpful if the SSA were required to screen
every case to determine whether a Work Incentives plan would
allow somebody to keep benefits that are about to be cut off. The
SSA should be required to provide "clear and convincing proof"
that someone is not entitled to a specific benefit before denying
it or cutting it off. ("Clear and convincing proof," the highest
civil standard of evidence, is the standard applied by the new
Rehabilitation Act to state Vocational Rehabilitation agencies
that wish to deny services to persons with disabilities.)
Already, Congress requires the SSA to interpret the PASS rules as
broadly as possible to serve the greatest number of persons, and
to assist PASS applicants whose plans are faulty. If the SSA
begins to devote as much staff time and effort to making the Work
Incentives system work in a positive way as some SSA employees
spend searching for reasons to reject Work Incentives plans and
cut off a consumer's benefits, then these new requirements will
not pose any additional burden on the SSA.
     The SSA needs to begin to devote more of its multi-million
dollar budget for publicity and public education each year to
spreading the word about Work Incentives outside the agency. The
SSA could start by reaching out to state vocational
rehabilitation agencies, independent living centers, advocacy
groups, vocational facilities and other public and private
agencies that serve persons with disabilities. In the long run,
the SSA should also be required to develop a campaign of
education aimed directly at persons with disabilities themselves.
To help bring this about, persons with disabilities and the
professionals that work with them need to do three things first:
     1) Educate ourselves and each other about the Work
Incentives; 
     2) Insist on the benefits that we are entitled to, even if
they are denied to us at first (or even if they are denied to us
a hundred times); and 
     3) Advocate with Congress, the White House and the Social
Security Administration itself to see the Work Incentives system
made workable. 
     This Guide is part of that campaign. If thousands of
informed persons with disabilities begin to demand what they are
entitled to, a "critical mass" will form and begin to break down
the barriers that have been put up inside the SSA to prevent
persons with disabilities from using the Work Incentives.
Congress probably will not want to expand the Work Incentives
system until the Federal deficit is brought under control
(although a case could be made that if the problems with the Work
Incentives system were fixed, more persons with disabilities
would be working -- and the Federal and state governments would
be spending less money on entitlement programs to care for them).
     Still, if it were politically possible, it would be
advantageous to recreate some of the SSA Work Incentives along
the lines of the Work Incentives available to people who receive
the Social Security Old Age Pension. They can earn up to $7,400
without any penalty; if they earn more they lose only $1 of
Social Security benefits for every $2 they earn. Once you reach
the age of 70, there is no penalty for working at all. Moreover,
the amount an Old Age Pension recipient may earn is indexed to
inflation, so it goes up automatically every year. Many activists
would like  SSI and SSDI recipients to get the same deal, but
Congress is likely to balk at the costs.
     A more modest and more achievable goal would be to switch
IRWE from an income exclusion to an income support. Disabled
workers would then receive the actual amount of the work expenses
associated with their disability, which would directly subsidize
their employment needs. It would also be helpful to allow SSI
recipients to earn $500/$810 per month without penalty, just as
SSDI recipients do, and allow them the same "buffer-zone"
benefits that SSDI recipients enjoy: a Trial Work Period and an
Extended Period of Eligibility. Since statistics show that people
with little or no work history before they become disabled have
the hardest time making the transition to employment, they
deserve every break that could be given to them.
     We have some optimistic news to report in this Second
Edition of the Guide. The Social Security Administration has
taken a new interest in the Work Incentives, and SSA employees
report to us that there are more Work Incentives trainings going
on now than ever before. Graduating to Independence, a
combination of printed material, a video and some computer
software, has been developed to encourage young persons with
disabilities in school-to-work transition plans to take an
interest in the Work Incentives. Rumor has it that soon the SSA
Field Offices will be given quotas of Work Incentives plans to
handle each year, which would encourage them to do more outreach
to persons who could be using the Work Incentives. Things seem to
be looking up!

SUBSIDIZED HOUSING, FOOD STAMPS,  AFDC, & GENERAL RELIEF

     Food Stamps, AFDC and General Relief are the three joint
Federal/state programs which, along with Medicaid, are
collectively are known as "welfare." Food Stamps are coupons
issued by the Department of Agriculture to help people with very
low incomes buy food. Aid to Families with Dependent Children
(AFDC) supports families with minor children. General Relief
provides an income to unemployed persons who don't qualify for
unemployment insurance, SSI, SSDI, AFDC, or other income
assistance. Each of these programs is "voluntary," in that a
state can choose whether or not to participate. Most states offer
AFDC and Food Stamps, but General Relief is becoming rare, a
casualty of tight budgets and the recession. If you receive any
of these benefits, they will probably be drastically cut or
eliminated when you begin to work, unless you are careful to do
some research first. 
     Every state that participates in one of these three welfare
programs is supposed to provide services to persons who are
leaving welfare to become self-sufficient. These programs are
sometimes referred to as "workfare." "Workfare" should help you
keep some of your benefits after you return to work, for a while
at least. Unfortunately, there is so much variability between
"workfare" programs from one state to the next that they make the
Social Security Administration Work Incentives look like a model
of simplicity and careful centralized planning. We have no way of
guessing what welfare benefits you may be able to keep in your
state; and there will probably be differences between the
benefits offered from one town to the next, since some "workfare"
programs are administered by local advisory councils. We suggest
that you consult with your welfare caseworker(s) well before you
are ready to return to work and explain what you are trying to
do. He or she will have to guide you. Hint: Your local Job
Training Partnership of America program (JTPA) is almost always
going to be part of the local "workfare" system. If your
caseworker can't or won't help, try the JTPA. 
     In some states, you may automatically be enrolled in
"work-fare" whether you think you are ready to work or not,
because the Federal Government encourages states to have high
rates of enrollment in "workfare," whether they are realistic or
not.
     Subsidized housing programs are administered by local
authorities, charitable groups and private contractors on behalf
of the Federal Department of Housing and Urban Development (HUD).
HUD does not have a set of formal Work Incentives, but many HUD
programs, including Section 202 housing for elderly and disabled
persons and Section 8 housing subsidies, will allow you to remain
in subsidized housing after you return to work -- at least for a
while. You will have to pay a higher rent as your income goes up,
and you rent will probably be based solely on your gross monthly
income. (In other words, HUD doesn't recognize PASS, IRWE or
other income exclusions, though they do sometimes reduce your
monthly rent by the amount of your monthly medical costs.)
Chances are, the manager of the subsidized housing where you live
is not familiar with the rules that will allow you to stay in
subsidized housing; he or she may think you have to move out as
soon as you start work. It is not a good idea to simultaneously
burden yourself with starting work and moving, and it may not be
practical financially, either. Ask the manager to check with your
state or regional HUD office to determine what kind of rent
adjustment might allow you to stay in your present housing for a
while. 
     Once again, we suggest you do your research well before you
figure on starting work. If you find out that you need to move
out of your subsidized housing, you need to know that as early as
possible.

VETERAN'S AFFAIRS WORK INCENTIVES
     Benefits to veterans of the United States Armed Services are
administered by the Federal Department of Veterans' Affairs (or
"VA" for short). They include the VA Pension, the VA
Compensation, VA Vocational Rehabilitation, the Housing and
Automobile Grants and medical services. 
     The VA Compensation is given to veterans who became disabled
while in the service or because of something that happened to
them while they were in the service; in other words, their
disability is "service-connected." The VA Pension is given to
eligible veterans with non-service connected disabilities. The
VA's program of Vocational Rehabilitation (VA/VR, for short) is
available to veterans with service-connected disabilities who are
considered medically able to work, while the Housing and
Automobile Grants are available to eligible veterans with
disabilities who want to buy an accessible house or adapted
vehicle.
     Service-connected disabilities are judged on a percentage
basis: a veteran may be 10%, 50%, 100% or some other percentage
disabled. The amount of VA Compensation is based on the
percentage-level of the veteran's disability. The greater the
percentage of disability, the higher the pension. The medical
services a veteran is eligible for depend on the type of
disability the veteran has. A similar evaluation system is used
to determine the amount of VA Pension that a veteran with a
non-service connected disability is eligible for. A veteran with
more than one disability, service-connected or not, can receive
percentage points for each disability.
     VA Compensation, VA Medical Services and the Automobile and
Housing Grants are lifelong benefits available to any veteran who
receives them. They are not reduced or eliminated when a veteran
returns to work; the veteran continues to receive his or her full
benefits. As far as these benefits are concerned, there is no
"work penalty." (This has certain advantages over the way Social
Security Recipients are treated when they return to work.)
     A veteran who receives a VA Pension may lose some benefits
when he or she returns to work. A VA Pension is calculated on the
basis of a veteran's income, as well as the nature and extent of
the veteran's disability. (A veteran whose disability gets worse,
or a veteran whose income declines, may get an increase in his or
her VA Pension.) A veteran with a VA Pension does not get a
"Grace Period" of a few months to collect his or her pension
while starting to earn a paycheck. The benefits will be reduced
as soon as the VA is informed of the change in the veteran's
income. (The IRS will probably furnish this information to the VA
almost at once, just as it provides this information to the
Social Security Administration.)
     Some veterans who are only 60% disabled still have a hard
time finding self-supporting work, so they receive a "Code 18
100% Unemployability" benefit. Sixty percent of the veteran's
disability must be caused by one specific disability, and there
must be verifiable complicating factors that prevent the veteran
from sustaining employment. (These factors can include one or
more non-service connected disabilities.) 
     The "Code 18 100% Unemployability" benefit has to be renewed
periodically; the veteran receiving it has to certify that he or
she has not worked. A veteran who receives a "Code 18 100%
Unemployability" benefit is qualified for Veterans' Affairs
Vocational Rehabilitation, but theses VR/VR benefits stop as soon
as the veteran finishes training, whether or not the veteran has
a job.
     VA Vocational Rehabilitation can pay for up to 48 months of
training at a vocational school or college. VA/VR services
include full payments for tuition, books and tools, as well as a
stipend for dependents. The VA Prosthetics unit, a branch of the
Medical Services program, provides wheelchairs, prosthetics,
specialized equipment and furniture, wheelchair cushions, braces
and any other kind of durable medical equipment the veteran
needs. A veteran is eligible for VA/VR services if he or she is
medically stable and passes evaluations and diagnostic tests to
prove that he or she is suited for the career he or she intends
to pursue.
     Veterans who think they may be eligible for any of these
services need to apply for them at their nearest VA Local Service
Office. (For many of you, this may mean traveling to a different
city. The VA will pay your travel expenses under some
circumstances.) 
     All states have a comprehensive system of Local Veterans'
Services that includes counselors who can advise you or help you
apply for benefits; check your phone book for a County Veterans'
Services Office, or check with your local veterans' groups. (Some
veterans' groups, such as the Paralyzed Veterans of America, 
have their own benefits counselors.)

WORK INCENTIVES IN THE FEDERAL TAX CODES (IRS WORK INCENTIVES)

     Believe it or not, the Infernal Revenue Service (sic) has
several Work Incentives you can take advantage of. They usually
kick in just as your income is starting to rise past the point
where you can no longer use Social Security Work Incentives. This
provides you with a smoother transition off your Social Security
Work Incentives, just as your Social Security Work Incentives
provide with a smoother transition from receiving benefits into
working. SSA Work Incentives will help you get an entry-level job
and begin to climb the ladder of success; the IRS Work Incentives
will help you as your income increases and you move closer to
financial security. You can always claim your IRS Work
Incentives, no matter how rich you get.
     Be forewarned -- IRS rules make the Social Security
Administration's rules look simple and well-organized. As a
matter of fact, the IRS's procedures make the Social Security
Administration look like a model of efficiency. A Congressional
study showed that only 60% of a sample of people who called the
IRS for tax advice got correct answers. For this reason, we
suggest that if you use IRS Work Incentives extensively, you get
professional help to prepare your taxes. If you cannot afford to
hire a professional tax accountant, there are a number of
voluntary agencies that can provide you with tax-preparation
help. Contact your local IRS office or your local chapter of the
American Association of Retired Persons. (The AARP has the
largest and best-trained cadre of tax-preparation volunteers, and
their volunteers often have personal experience dealing with many
of the IRS Work Incentives.)
     Remember, no matter who advised you or prepared your taxes,
the IRS will hold you responsible for any errors -- so be
careful. Of course, the IRS will hold you responsible even if the
person who gave you the bad advice was an IRS employee -- so
there really isn't any security anywhere. However, if you can
prove in writing that an IRS employee advised you incorrectly,
you will only be liable for back taxes and any interest on them
-- not the penalty. Therefore, anytime somebody from the IRS
tells you something, get it in writing. This could be your only
defense in case of a slip-up.
     You should also be aware that Congress changes parts of the
Tax Code every year. Therefore, this section of your Guide will
only discuss the IRS Work Incentives in general terms. Consult
current IRS tax guides (available at your local library, IRS
Field Office, or Post Office) for specific details on the current
rules. The most important guide to obtain is the Information for
Persons with Handicaps or Disabilities, IRS Pub. # 907.
     
MEDICAL CARE DEDUCTIONS
     All of your medical care expenses are tax-deductible. This
includes your work-related medical expenses, such as wheelchair
repair, personal care, medications, adaptive equipment, etc. The
catch is that if you claim an unusually large percentage of your
income -- such as $5,500 out of annual earnings of $20,000 -- you
can be certain that at some point you will be audited by the IRS,
because their computers will "flag" your return for further
study. 
     The best way to insure that all of your medical expenses are
honored as tax deductions is to make sure you have current
prescriptions from a physician for everything you buy and every
service you pay for: bedpads, catheters, wheelchairs, personal
assistance services, home modifications, etc. Even if you don't
have to present a prescription when you buy something (like
bedpads or a wheelchair cushion), having the prescription
verifies the necessity of the items or services, and covers you
by establishing their deductibility.
     Note: If you pay your personal care assistant directly, the
IRS will want you to take out taxes, FICA and unemployment
insurance. If you don't, you could be fined and hit for the back
taxes. The IRS will be extra sticky about this if you have been
taking the tax deduction for using a personal care assistance,
without withholding the taxes, Social Security and unemployment
insurance for your assistant(s). You need to get a copy of IRS
Publication 926, Employment Taxes for Household Employers and
follow the procedures in the book, a tedious but necessary chore.
(A great deal of attention has been focused on this issue
recently because of the revelation that two of President
Clinton's nominees for the office of Attorney General hired
baby-sitters without paying their FICA.)
     Certain disability-related expenses are not considered
"medical" by the IRS, such as paratransit fees, vehicle
modification costs, readers, adaptive equipment used only on the
job, guide dog expenses, etc.These go under the IRS version of
IRWE.
     How to Apply: File Form 1040, using the Schedule A form. You
will need the instruction book for Form 1040. 
     Records You Will Need to Keep: 1) an itemized, day-by-day
log of all medical expenses; 2) all bills, receipts,
prescriptions, invoices and canceled checks, filed in
chronological order; 4) the withholding records required from you
as an employer (outlined in IRS Publication 503); and 5) copies
of all your tax returns and correspondence with the IRS. You
would do best to use the same recordkeeping procedures and
precautions we described above for people who use Social Security
Work Incentives.
     A sample Medical Expenses Log appears at the end of this
Guide. We recommend you pay all your deductible medical expenses
with checks, to establish the proper "paper trail."

IMPAIRMENT-RELATED WORK EXPENSES
     The IRS version of IRWE works very much like the SSA
version. It allows you to take a tax deduction for any and all
expenses you must pay in order to hold a job -- as long as they
are related to your impairment. Durable medical equipment,
medications, doctor's bills and other medical expenses are
covered under the Medical Care Deductions, and Personal
Assistance is also covered as a Medical Care Deduction, so the
IRS IRWE is used for items such as van modification, specialized
computer equipment, reader services,  paratransit, etc. The IRS
IRWE becomes available to you as your income rises too high to
use the SSA IRWE, so that you can begin to take your
Impairment-Related Work Expenses as tax deductions, rather than
SSA income exclusions. Unlike other Employee Business Expenses,
the IRS IRWE are not subject to the 2% of adjusted gross income
limit. This makes the IRS IRWE one of the most effective and
far-reaching of all the Federal Work Incentives.

CREDIT FOR THE ELDERLY AND DISABLED
     You may claim the Credit for the Elderly and the Disabled
during your SSA Trial Work Period, as long as your work is not
gainful and substantial. (Your work may be either "gainful" or
"substantial," but not both.) 
     The IRS may judge "gainful" and "substantial" differently
from the Social Security Administration, so check with your local
IRS office before you try to claim the Credit for the Elderly and
Disabled.
     How to Apply: File Schedule R along with your Form 1040. You
will need a copy of IRS Publication 524, the instructions booklet
for Schedule R.
     Records You Will Need to Keep: 1) Your SSA Work Incentives
records; 2) copies or stubs of all your paychecks and 3) copies
of all your tax returns and 4) copies of all your  correspondence
with the IRS and the SSA. A sample Income Log from appears at the
end of this Guide. You can use it to record your income; be sure
to log every check, from every source.


CHILD AND DEPENDENT CARE CREDIT
     This is a Work Incentive for caregivers. If you pay someone
to look after a disabled child or other disabled dependent, you
can claim a credit for the cost of that care. You must be paying
for the care in order to free you up to work outside the home,
the person who receives the care must be somebody you legally
claim on your taxes as a dependent and he or she must be
"totally" disabled. Generally speaking, the IRS won't consider
anybody "totally" disabled unless he or she could receive SSI or
SSDI; however, there is no requirement that your dependent
actually receive SSI or SSDI, and you could claim somebody with a
temporary disability as a "totally" disabled dependent (such as
child recovering from surgery). Be prepared to go to a lot more
trouble documenting a "total" disability if your dependent does
not receive SSI or SSDI.
     How to Apply: File Form 2441 with your 1040 and Schedule A.
You will need the instruction book for From 2441. Also, get IRS
Publication 503, "Child and Dependent Care Expenses," for more
information.
     Records You Will Need to Keep: 1) The withholding records
required of you as an employer (see above, "MEDICAL CARE
DEDUCTIONS"); 2) verification of your dependent's disability; and
3) copies of your tax returns and all other correspondence with
the IRS.

THE ADA TAX CREDIT
     This is not a tax deduction directly available to you as a
disabled jobseeker. Rather, it is a tax credit your employer can
take to cover part of the costs of making his or her business
accessible. It is available to businesses with gross receipts of
less than $1 million in 1992, which also employ fewer than 30
full-time employees.
     Although the ADA Tax Credit is not a Work Incentive for you
directly, it may help you to understand the ADA Tax Credit if you
plan to apply for work at a small business. If your prospective
employer expresses concern about the costs of accommodating you
in his or her business, you need to be able to explain that the
ADA Tax Credit will cover many of the costs. The ADA Tax Credit
was passed into law by Congress for the purpose of helping small
businesses to make themselves accessible in cases where this
might otherwise be an "undue burden" that would leave them exempt
from the law.
     The ADA Tax Credit differs from the tax deduction previously
available to business owners who made their facilities
accessible. When you take a tax deduction, you only get to write
off a portion of the deduction on your taxes. When you take a tax
credit, you can take the whole value of the credit off your
taxes.
     A qualified small business can take the credit for
renovations, the cost of TDDs, the cost of adaptive devices and
cost of removing transportation barriers. Any sections of a
building that are renovated must be brought up to the Uniform
Federal Accessibility Standard (UFAS), which is similar to the
basis for most state accessibility codes and the Americans with
Disabilities Act Architectural Guidelines. The ADA Tax Credit
will cover all the costs of ADA compliance between $250 and
$10,250 per year. Half of all costs incurred (up to $30,000) can
be taken in the Tax Credit, for a total of up to $15,000.
Sadly, many small-business owners who have heard of the ADA Tax
Credit are convinced that it is too difficult to obtain because
members of the IRS staff are not knowledgeable enough about it to
process the claims correctly. Many times when small businesses
filed for the old tax deduction, perfectly valid claims were
rejected for just this reason. (Sound familiar?) The only
solution to this problem, of course, is for those who are
entitled to the ADA Tax Credit to claim it and insist that their
claims be honored.
     How to Apply: Your employer needs to apply. He or she can
obtain more information about the ADA Tax Credit by contacting
Mark Pitzer, Office of the Chief Counsel, Internal Revenue
Service, 1111 Constitution Ave. NW, Washington DC 20224.
     Records You Will Need to Keep: None. The recordkeeping
responsibility belongs to your employer.

THE TARGETED JOBS TAX CREDIT 
(SECTION 51 OF THE INTERNAL REVENUE CODE)
     Like the ADA Tax Credit, the Targeted Jobs Tax Credit is a
"Work Incentive" for your employer. The TJTC program rewards
businesses of any size that hire persons in nine "targeted"
groups, including people with disabilities.
Like the ADA Tax Credit described above, the TJTC is a tax credit
-- which means the full value of the TJTC may be taken off an
employers taxes. All for-profit businesses are eligible for a
TJTC. A business may hire as many people eligible for a TJTC as
it can, and take a TJTC for each one. There is no limit to the
total tax credit an employer may accumulate under the TJTC
program.
     For every disabled employee a business hires, it may take a
TJTC for 40% of the disabled employees first-year wages, up to
$6,000. The per-person limit on a TJTC is $2,440. The disabled
worker may be full or part-time, but must either hold the job for
90 days or complete 120 hours of work. The employer must reduce
his or her deduction for employee wages by the size of the TJTC
claimed, which slightly reduces the value of the credit.
     The procedure for claiming a TJTC is somewhat complex.
First, you have to obtain a TJTC voucher from your local
Vocational Rehabilitation or Job Training Partnership of America
office. In some states, you must already be a VR or JTPA client
to get the TJTC voucher, or else become one in order to get the
TJTC voucher. Give this to your employer when you start work.
Your employer must complete one of the sections on the voucher
and then mail it to the nearest Employment Service office. The
Employment Service will send your employer back a certificate
which validates the TJTC. Your employer then submits the
certificate to the IRS at tax time.
     The TJTC offers large businesses a chance to recoup some of
the costs of hiring a worker with a disability, and offers
smaller businesses an additional incentive on top of their ADA
Tax Credit.
     Note: The Targeted Jobs Tax Credit program must be renewed
each year by Congress, and is frequently the subject of severe
criticism. Before you count on using a TJTC, check with your
local JTPA to be sure it is still in force.
How to Apply: Contact your local Vocational Rehabilitation or
JTPA office.
     Records You Will Need to Keep: A copy of the voucher form,
after it has been filled out and signed by your employer.

THE AUTHOR'S FINAL NOTE: A FEW WORDS OF ENCOURAGEMENT
     I have tried to give you a realistic picture of the
obstacles you may encounter in planning and claiming Federal Work
Incentives benefits, but I don't want to discourage you. The Work
Incentives were created for your use, to help you get over
financial and other barriers that may be keeping you out of the
job market. Thousands of people with disabilities have used the
Work Incentives successfully. With patience, persistence and
assertiveness, you'll be one of the success stories, too. 
I hope this has Guide has started you thinking about using the
Federal Work Incentives to help you enter the job market. If you
have questions or problems with the Social Security
Administration that aren't covered in the Red Book, and your
local Social Security Office can't or won't help you, contact me
weekdays between 2 PM and 5 PM (EST) at the Center for
Independent Living of North Florida, Inc.

John Woodward, M.S.W.
CIL of North Florida, Inc.
1380 Ocala Rd H-4
Tallahassee FL 32304
Voice/TDD: (800) 226-9621
FAX: (904) 575-5740
Internet E-mail: woodward@freenet.scri.fsu.edu

     I will be glad to help out as many people as I can, as long
as I can fit it in with my regular duties. (I'd love to hear your
tips, suggestions, ideas for improving this Guide and "success
stories," too!)
     Meanwhile, feel free to make as many copies of this Guide as
you wish. (It's not copyrighted.) Spread it around! I ask only
that you drop me a line to let me know how many copies you have
distributed, and where. (This information can be important to us
at the Center for funding purposes.) 
     I have been working for over two years to create that
"critical mass" I mentioned above, of educated consumers
demanding their rights. The feedback I have received from people
who have read earlier versions of this Guide, or articles based
upon it, leads me to believe that we're getting close. If 100,000
consumers see this Guide, and just half of them show up at an SSA
Field Office demanding their rights, we'd create a "blip on the
screen" that couldn't be ignored. Fifty thousand new applicants
would boost the SSA's Work Incentives recipients almost 33%, and
that's just the beginning! Imagine what will happen when every
school transition counselor, every vocational rehab counselor,
every rehabilitation facility operator, every independent living
advocate and every consumer advocacy group starts promoting the
Work Incentives: we'll start a revolution! 
     What are we waiting for? 


  This document may be distributed freely in electronic format.
SOME INSTRUCTIONS FOR USING THE SAMPLE FORMS

     These sample forms have been developed to help you keep the
records you will need to use the Social Security Work Incentives.
(Some of them can also help you keep the records you will need
for the Internal Revenue Service.) Although they have been
reviewed by employees of the SSA, they are not in any sense
"officially-approved" SSA forms. However, we think they'll cover
most of your recordkeeping needs. As we said before, though, you
need to discuss recordkeeping with the SSA staff member(s) who
review your Work Incentives plans.
     The Income Log will record your income. Log in each check as
you receive it. Be sure to include all your income, from whatever
source. Save any W-2s you get from employers, and Notices of
Award from the SSA, as well.
     There are two forms for your Blind Work Expenses: and
Estimate form an Actual Expenses Paid form. Use the Estimate form
to estimate your annual Blind Work Expenses, taking care to
specify whether each expense you enter is annual, quarterly or
monthly. Annual expenses must be divided by twelve to yield a
monthly sum, and quarterly expenses must be divided by three. The
Actual Expenses form will record the expenses as you pay them.
(Remember, for the purposes of Blind Work Expenses, your FICA and
other payroll taxes are a "work expense.") As we suggested
earlier, always pay Work Incentives expenses with a check to
develop a proper "paper trail."
     There are two forms for your Impairment-Related Work
Expenses: an Estimate form and an Actual Expenses Paid form. Use
the Estimate form to estimate your annual Impairment-Related Work
Expenses, taking care to specify whether each expense you enter
is annual, quarterly or monthly. Annual expenses must be divided
by twelve to yield a monthly sum, and quarterly expenses must be
divided by three. The Actual Expenses form will record the
expenses as you pay them. As we suggested earlier, always pay
Work Incentives expenses with a check to develop a proper "paper
trail."
     There are two forms for your PASS Expenses: an Estimate form
and an Actual Expenses Paid form. (These are meant to supplement
the forms that you will be provided in your PASS application.)
Use the Estimate form to estimate your annual Impairment-Related
Work Expenses, taking care to specify whether each expense you
enter is annual, quarterly or monthly. Annual expenses must be
divided by twelve to yield a monthly sum, and quarterly expenses
must be divided by three. The Actual Expenses form will record
the expenses as you pay them. As we suggested earlier, always pay
Work Incentives expenses with a check to develop a proper "paper
trail." (The Actual Expenses form can track your IRWEs for the
IRS, as well as your SSA IRWEs.)
     The Medical Expenses Log will record all your medical
expenses, including co-payments and Medicare premiums. These need
to be recorded for IRWE and for the IRS Medical Deductions.
The Depreciation Schedule supplements your IRWE and PASS forms.
Once you have computed the amount of money you will be setting
aside each month for depreciation, enter a "Depreciation" line
item in your PASS or IRWE form. Attach the Depreciation Schedule
form to your PASS or IRWE forms.




















































INCOME LOG

FROM:               TO:

AMOUNT         CHECK NUMBER:            SOURCE:        DATE:


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QUARTERLY TOTALS:

WORK INCOME:             BENEFITS:           OTHER:


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BLIND WORK EXPENSES

ESTIMATE FOR THE YEAR OF: ____________

AMOUNT    TYPE OF EXPENSE          MONTHLY,            MONTHLY
                                   QUARTERLY OR        AMOUNT
                                   ANNUAL?


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TOTAL ANNUAL EXPENSES:             TOTAL MONTHLY EXPENSES:
BLIND WORK EXPENSES

ACTUAL EXPENSES PAID FOR THE MONTH OF: ___________ YEAR: _____

AMOUNT         CHECK NUMBER:  EXPENSE:            DATE:


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TOTAL BLIND WORK EXPENSES FOR THE MONTH:
IRWE EXPENSES

ESTIMATE FOR THE YEAR OF:_____________

AMOUNT         TYPE OF EXPENSE          MONTHLY,       MONTHLY
                                        QUARTERLY      AMOUNT
                                        OR ANNUAL?


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TOTAL ANNUAL EXPENSES:             TOTAL MONTHLY EXPENSES:
IRWE EXPENSES LOG

ACTUAL EXPENSES PAID FOR THE MONTH OF:____________ YEAR:_____

AMOUNT:        CHECK NUMBER:       EXPENSE:            DATE:
                                        
                                        


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TOTAL IRWE EXPENSES FOR THE MONTH:



PASS EXPENSES

ESTIMATE FOR THE YEAR OF:_____________

AMOUNT:        TYPE OF EXPENSE          MONTHLY,       MONTHLY
                                        QUARTERLY      AMOUNT
                                        OR ANNUAL?


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TOTAL ANNUAL EXPENSES:             TOTAL MONTHLY EXPENSES:


PASS EXPENSES LOG

ACTUAL EXPENSES PAID FOR THE MONTH OF:____________ YEAR:_____

AMOUNT:        CHECK NUMBER:       EXPENSE:            DATE:
                                        
                                        


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TOTAL PASS EXPENSES FOR THE MONTH:


MEDICAL EXPENSES LOG

MONTH OF:____________ YEAR:_____

AMOUNT:        CHECK NUMBER:       EXPENSE:            DATE:
                                        
                                        


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DEPRECIATION SCHEDULE

ITEM           REPLACEMENT COST         YEARS OF       MONTHLY
               (CURRENT COST + 15%)     EXPECTED LIFE  DEPREC.

                                        


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TOTAL ANNUAL DEPRECIATION:         MONTHLY DEPRECIATION:

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ADDRESSES OF THE SOCIAL SECURITY ADMINISTRATION REGIONAL OFFICES:

REGION 1                           REGION 2
Regional Commissioner, SSA         Regional Commissioner, SSA
Attn: Disability Programs          Attn: Disability Programs
Room 1100                          Room 40-102
JFK Federal Building               Federal Building
Cambridge St.                      26 Federal Plaza
Boston MA 02203                    New York NY 10278

REGION 3                           REGION 4
Regional Commissioner, SSA         Regional Commissioner, SSA
Attn: Disability Programs          Attn: Disability Programs
PO Box 8788                        PO Box 902
Philadelphia PA 19104              Atlanta GA 30323

REGION 5                           REGION 6
Regional Commissioner, SSA         Regional Commissioner, SSA
Attn: Disability Programs          Attn: Disability Programs
10th Floor                         Room 1440
105 Adams St.                      1200 Main Tower Bldg.
Chicago IL 60603                   Dallas TX 75202

REGION 7                           REGION 8
Regional Commissioner, SSA         Regional Commissioner, SSA
Attn: Disability Programs          Attn: Disability Programs
Room 436, FOB                      Room 1194, FOB
Kansas City MO 64106               Denver CO 80294

REGION 9                           REGION 10
Regional Commissioner, SSA         Regional Commissioner, SSA
Attn: Disability Programs          Attn: Disability Programs
75 Hawthorne St.                   2001 Sixth Ave. M/S RX-50
San Francisco CA 94105             Seattle WA 98121



This document may be distributed freely in electronic format.

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