Chapter 12: Plan for Achieving Self-Support (PASS)
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Table of Contents

Purpose for a PASS
Effects of PASS on Benefits
PASS Summary
Earned and Unearned Income
Resources
PASS Approval Requirements
Examples of Possible PASS Expenditures
Non-Approvable Expenditures
Supported Employment as an Excludable Expense
PASS Candidates
Developing a PASS
Starting a Business Under a PASS
Components of a Business Plan
Calculating a PASS
Two Factors Affecting PASS and SSI Check Amount
Effect of the One-Third Reduction Rule (Full In-Kind Support)
The Presumed Maximum Value Rule (Partial In-Kind Support)
Deciding Between PASS and IRWE
Concurrent PASS and IRWE
PASS and Social Security
Final Comments on PASS
PASS Case Study
PASS Format
PASS Review Process
Exhibit 1 -- Initial PASS Checklist
Exhibit 2 -- PASS Progress Review
SSI / Social Security Comparison Chart
Concurrent Exercise

Purpose for a PASS
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PASS is an SSI work incentive under which persons with disabilities can set aside income and/or resources to be used to achieve specific work goals. A PASS can be established to cover the costs of obtaining an education, receiving vocational training, starting a business, or purchasing support services which enable individuals to work and result in reduction/cessation of benefits (SSI/SSDI). These support services may include:

 

* The purchase of coaching/job advocacy supports needed to obtain / maintain employment;

* Vocational evaluation;

* The payment of transportation-related expenses;

* The purchase of job-related equipment, uniforms, etc.;

* The mechanism for allowing individuals or groups of individuals to purchase a business; and

* Any other services/equipment needed to support individuals in a work-related manner.

 

In April 1996, SSA revised its guidelines for administration of the PASS Program and created a new process for handling PASS applications and reviews. From the onset of the initial changes to PASS, SSA informed Congress and consumers that it would assess the impact of these new guidelines. The primary purpose for these changes was to ensure proper stewardship of the provision, in light of recent findings by the General Accounting Office that the program was being misused and mismanaged.

 

While this assessment began in March of 1997, it was greatly accelerated by expressions of concerns by PASS applicants and participants regarding adverse impact of the enhancements and lack of consistent application of PASS guidelines across the United States. This assessment of the enhancements to the PASS Program was followed on December 1, 1997 with a statement made by Carolyn W. Colvin, Deputy Commissioner for Programs and Policy, Social Security Administration, which further amended the procedures for applying PASS policies, and the overall process for handling the work associated with PASS applications and reviews. The information outlined in this chapter includes these recent changes and SSA has recently issued complete instructions to its field offices via POMS, which incorporates all of these changes. Individuals having difficulty accessing the PASS Program, desiring addition information, or interested in providing customer feedback should contact SSA.



Effects of PASS on Benefits
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PASS is simply the means to acquire the services and items needed for starting work, not the means to make income or resources available for ongoing costs. The purpose of a PASS is to increase or maintain income-producing capabilities, thus reducing individuals' reliance on government benefit support. For a PASS to be approved by SSA, there must be a reasonable chance that individuals can achieve their vocational goal. There must also be a clear connection between the vocational goals and the increased or maintained earning capacities. PASS is meant to assist a person in competing in the job market. PASS makes it financially feasible for individuals to set aside or save income and/or resources. These can be used to achieve vocational goals by enabling individuals to receive higher SSI payments as they work toward self-sufficiency. The PASS program provides persons with disabilities the opportunity to self-direct the vocational rehabilitation process.



PASS Summary
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A PASS is meant to be a flexible tool to allow individuals with disabilities to either raise their SSI amount or become eligible for SSI, in order to obtain items or services that would help them return to work or increase their ability to support themselves by earning more than they currently are. A PASS gives additional SSI income to help individuals become less dependent on SSI at the end of the PASS.

 

The income and/or resources set aside in a PASS are not counted in determining eligibility for SSI or in calculating the amount of the SSI benefit that individuals will receive. In determining SSI eligibility, individuals must meet an income and resources test. If their income (including earnings and unearned income such as Social Security) and/or resources are too high, they will not be eligible for SSI. However, by excluding this income and/or resources in a PASS, individuals could then meet the income and resources test, thus potentially qualifying for SSI.

 

This is how it works: The SSI amount is increased (or individuals are made eligible for SSI when they would not be under the regular SSI rules), by excluding certain income or assets (also called resources), which would have to be counted under the regular SSI rules. Income and resources, which normally would reduce SSI or prevent eligibility, can be ignored if they are listed in the PASS and used towards occupational objectives. The extra SSI helps pay for their other living expenses (i.e. food, clothing, and shelter).

 

In some cases, the extra SSI generated by a PASS will match the amount being spent in a PASS, so that the cost of the PASS is completely covered by the SSI increase. However, each PASS situation must be computed separately to find out. Even when the PASS does not replace the money spent dollar for dollar, there may be other factors that make a PASS advantageous, such as allowing Medicaid eligibility. The long-term benefits of a successful PASS, both financial and personal, may be worth an investment now.



Earned and Unearned Income
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Individuals who have both earned and unearned income can set aside either, or both, of these incomes as well as deemed income from a spouse or parent or in-kind income to establish, or increase, SSI cash benefits.

 

Earned Income:

If individuals who receive SSI were to go to work, their new earnings would result in the SSI check being reduced. Recipients' SSI checks would normally be reduced by the earnings, minus allowable exclusions (known as the countable earned income). By setting aside new earnings that would normally reduce the SSI check, individuals are provided with an opportunity to purchase the goods and services needed to work.

 

Unearned Income:

Individuals who have only unearned income in the form of Social Security or another type of pension may also benefit from the PASS work incentive. Depending on the amount of their countable unearned income, individuals may not be eligible for SSI, or if eligible, be receiving a reduced SSI check (i.e., they would not be receiving the maximum FBR.) By setting aside a portion, or all of this countable unearned income in the PASS, individuals may be able to increase the amount of the SSI check they are currently receiving.



Resources
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If individuals have resources that exceed the resource limit for SSI, these resources may be set aside in the PASS as well. Resources can be anything that is owned, including bank accounts, real estate, or personal property.

 

In summary, a PASS can be established by setting aside one or more of the following to achieve a vocational goal:

 

* Earned income (wages, self-employment, certain sick pay, royalties and or honoraria);

* Unearned income (Social Security or other types of benefits, or other types of monetary support); and/or

* Resources.

 

The PASS enables individuals to recoup some or all of the expenses paid for under the PASS.



PASS Approval Requirements
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For approval, each PASS must meet the following requirements:

 

1. Feasible Occupational Goal:

The PASS must be specifically designed for each individual and have a designated and feasible occupational objective. Non-occupational objectives, such as basic living skills or homemaking skills, do not meet PASS requirements. The proposed vocational goals must be clearly stated, indicating job titles or, if self-employed, the type of business. It is important to note the individuals' age, prior work history, education and training, disability, and if there is a reasonable chance for them to attain the objective. The PASS must also indicate current earnings, estimated earnings pending PASS completion, and/or level of independent job performance, which the individual expects to reach.

 

As part of SSA's assessment of the April 1996 enhancements to the PASS Program, they found that evaluations and notices did not make a clear distinction between the feasibility of the goal (based on a person's reasonable expectation to perform the work), and the viability of the plan for achieving it (based on the steps necessary to achieve the goal). Based on policy changes made on 12/1/97, operating instructions were modified to make a clear distinction between feasibility and viability, making sure the same distinction is made in all evaluations and notices sent to PASS applicants. As outlined in Carolyn Colvin's statement of 12/1/97, "unless there is evidence to the contrary, SSA's PASS Specialists will presume an occupational goal to be feasible, and the plan for achieving it to be viable, if any certain State or private professionals in the field of vocational rehabilitation and employment develops the PASS. If the PASS specialist cannot approve a PASS, he or she will discuss the matter with the individual as well as with the plan's preparer. If the PASS Specialist continues to believe that the goal is not feasible or the plan is not viable, he or she will document the file regarding the discussion and the reason for his or her position." If the PASS Specialists feel it is warranted, they may request the PASS applicant undergo a vocational assessment. If a vocational assessment is recommended, usually the cost of the assessment will be included as a PASS expense.

 

2. Limits on Occupational Goals

The December 1997 changes to PASS clearly stipulate that existing POMS instructions describing the limit on occupational goals was found to have an exception in the case when an "entry-level" position did not produce sufficient income to cover the individual's living expenses, uncovered medical expenses, and work-related expenses. The operating guidelines have been revised so that "within the business, trade, or profession the individual chooses, his or her occupational goal must be the earliest point on the career path at which earnings can reasonably be expected to cover his or her living expenses (as they exist during the PASS), uncovered medical expenses, and work-related expenses."

 

3. Interval Steps/Milestones:

The PASS must incorporate milestones and corresponding timeframes leading to attainment of the occupational objective. These demonstrate the person's progress toward achieving the goal and should be described sufficiently so that completion of steps is readily discernible. Milestones are best documented using criterion-based statements. This also includes the interval steps related to actually securing a job as stated in the occupational objective.

 

4. Definable Timeframe:

Specific time frames must be established for the PASS. Schedules must be provided for meeting the vocational goals, which indicate the month and year that it is expected to begin and end. The time allotted must be reasonable for achieving the goal and reflect the person's estimated time for completing the goal. [Based on individual needs, a PASS can be extended beyond the regulatory 36/48-month timeframe for a PASS in 6-month increments.]

 

5. Sources to be Set Aside:

Plans must state the sources and the amount of income or resources to be set aside, such as earnings, SSDI, benefit supports (other than SSI), savings accounts, extra family support, stock dividends, and loans. The sources, amounts and rates of accumulation of income and resources must be adequate, but not excessive, to achieve the goal. Plans must also show how income/resources set aside will be kept clearly and easily identifiable. Separate bank accounts for PASS savings are a good way to provide for verification of PASS savings and expenditures.

 

6. Expenditures:

The PASS must state how the money set aside will be spent to achieve the occupational objective. A list must be included of monthly planned expenditures by grouping or category with an explanation of their connection to the occupational objective. Expenses necessary for achieving the goal must be reasonable in price to be approved. Cost estimates for goods and services indicating how the costs were calculated should be included. Providers should be indicated when known. Goods and services under the PASS may be bought outright, rented or leased. In the case where an item of unusual value is to be purchased, the PASS must include a satisfactory justification as to why less expensive alternatives will not suffice. Some examples of items that may qualify as PASS expenditures include:

 

* Educational and training costs, tuition, books, additional costs for room and board while away from home, associated fees and costs;

* Equipment, tools, supplies, operating capital inventory, taxes, costs of fees and licenses;

* Medical and social services, attendant and child care, operational or access modifications to buildings or vehicles;

* Transportation costs and related finance, service and maintenance costs; and/or

* Attendant care and/or job coaches.

 

If there are questions about whether items or services are appropriate for inclusion under a PASS, please inquire! Take note that individuals who are denied a proposed PASS are entitled to the reason(s) in writing from the local SSA office.

 

Remember, PASS is just the means to acquire the services and items needed for starting work, not the means to make income or resources available for ongoing costs. Start-up costs reflect the costs required to obtain the needed goods or services to enable the person to start the job or business.

 

7. Major Purchases:

Per Carolyn Colvin's statement on 12/1/97 "allowable expenses for major purchases will not be limited to downpayments. Funds set aside for installment payments will be excluded to the extent that the expense remains related to, and supportive of, an approved occupational goal, and earnings do not negate the need to continue the exclusion." (This policy is in current instructions for field offices -- new POMS SI 00870.)

 

8. Organization:

The PASS must be in writing and SSA has established form SSA-545 to assist in completing a Comprehensive Plan. Individuals should use form SSA 545 when initiating a PASS. Any Social Security office can assist in writing the plan. Also there are PASS preparers, advocates for the disabled, agencies, organizations, etc. that can help with the form. Form SSA-545 is included on pages 159-172 and is also available on-line at SSA's website. If another format is used, the applicant will still be responsible for providing SSA with the essential information requested in SSA-545.

 

9. Deferred Expenses:

Not all expenses may be allowed at the beginning of the PASS. In some cases, approval of certain goods and services may be contingent on the successful completion of milestones on which the need of the expenses is predicated. Subsequently, no expense will be approved unless the milestone is completed.



Examples of Possible PASS Expenditures
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* Supported employment services such as job development and job coach services;

* Equipment, supplies, operating capital, and inventory required to establish a business;

* Tuition, books, supplies and all fees and costs imposed, by or in connection with, an educational or occupational training facility including tutoring, counseling, etc.;

* Attendant care;

* Child care;

* Additional costs incurred for room and board away from principal residence which is required to attend educational, training, employment, trade or business activities;

* Equipment or tools either specific to individuals' conditions or designed for general use (i.e., for individuals without disabilities);

* Dues and publications for academic or professional purposes;

* Uniforms, specialized clothing, safety equipment (everyday clothing is not allowable);

* Basic life skills training if currently pursuing an occupational objective and the training is necessary for attaining the objective;

* Medical and social services;

* Operational or access modifications to buildings or vehicles to accommodate disabilities;

* Least costly alternatives for transportation, including:

- Public transportation and common carriers,

- Hiring private or commercial carriers,

- Assistance with purchase of a private vehicle;

* Preparation fees for developing a PASS;

* Licenses, certifications and permits required for employment (government-imposed penalties, fines, or income taxes are not allowable.)



Non-Approvable Expenditures
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No expenditures will be approved that:

 

* Will not be paid by the income and resources set aside;

* Were in existence prior to initiation of the PASS goal, which can predate the submittal to SSA of the request for a PASS. (However, these could be incorporated as an IRWE/BWE if approvable);

* Were purchased under a prior PASS unless a satisfactory justification is provided;

* Is used to reduce countable income after the start-up period for a business. The use of an item as a business expense in determining taxes for business does not preclude using a PASS expense during the calendar years that encompass the start-up period;

* Not paid for by the individual or if the individual expects to be reimbursed for the expense.

 

Supported Employment as an Excludable Expense
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Individuals in a supported employment situation also may use a PASS to increase potential for self-support. This will generally occur through decreasing their costs for, and their reliance upon ongoing supports needed to work. An individual's objective is to work at a job with a certain level of independent performance as described in the plan. The goal may be to achieve stabilization or to reach an even higher level of performance.

 

The individual plan should specify the anticipated level of performance in terms of supports required. The plan should be amended if it appears the person can perform at a higher level.

 

Only the cost of actual job coaching services may be allowable as job coach expenses. A knowledgeable service, such as VR or employer, may be contacted to verify the need for coaching and the chance for increased independence. The reasonable allowable charge for these services will reflect the amount the local state VR pays for similar services.

 

While extended or follow-along services generally would not be allowable under a PASS, they may qualify if the individual is seeking to increase his/her potential for self-support.



PASS Candidates
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To qualify for a PASS, an individual must meet the following criteria:

 

* Be under age 65 (unless receiving SSI disability payments in the month before age 65);

* Be disabled or blind;

* Meet all eligibility requirements for SSI with the exception of the income and resources test;

* Have earnings, unearned income deemed income, in-kind income, or resources to set aside in the PASS. (Examples of unearned income include Social Security, private pension, monetary support or gifts from family or friends); and

* Have expenses related to achieving the work goal.

 

Likely Candidates:

 

* Resources in Excess of Allowable Limits:

Individuals who do not have earned or unearned income and have not qualified for SSI in the past due to resources in excess of the resource limit. By establishing a PASS to set aside these resources to achieve a vocational goal, individuals can qualify for SSI.

 

* Unearned Income Only:

Individuals who have unearned income only can establish a PASS to exclude the unearned income, thus establishing SSI.

 

* Earned Income Only:

Individuals who have earned income only can set aside earnings in the PASS and begin receiving SSI checks, although PASS does not affect the SGA determination that is required for initial eligibility.

 

* Both Earned and Unearned Income:

Individuals who have earned income and unearned income can set aside their wages, Social Security or both to establish SSI cash benefits. Again, PASS doesn't affect the SGA determination required during initial eligibility.

 

* Earned Income and Receiving SSI:

Individuals who have earned income and are receiving SSI can set the earnings aside in a PASS to increase the amount of their SSI check. This same situation is true for persons who have unearned income and receive SSI prior to PASS.

 

* Earned Income (in near future) and Receiving SSI:

Individuals who have SSI only but will begin working in the near future can establish a PASS to set aside the new wages starting with the first month of employment. The SSI check will only be reduced by the amount of countable earnings not set in the PASS.

 

* Potential PASS candidates having income/resources include those individuals in school or training programs, currently receiving services from rehabilitation agencies, or interested in rehabilitation and becoming self-supporting.

 

Not Likely Candidates:

 

* Individuals ineligible for SSI for reasons other than excess income and/or resources.

* Individuals who are unable to pursue occupational goals due to their mental/physical condition.

* Individuals who are currently self-supporting.

* Individuals who have already completed a PASS and have not tried to seek employment in the work goal for a prior approved PASS.

* Individuals who do not have resources or income to set aside and do not expect any.

* Individuals who do not need items or services to work.

* Individuals who are NOT willing to set aside funds for PASS.

 

Developing a PASS
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The development of a PASS may begin at any time. If individuals establishing the PASS are already receiving SSI, meeting initial SSI eligibility criteria is not required. If individuals are currently not receiving SSI, they must go through the regular SSI application procedure before a PASS can result in an SSI check being issued.

 

Remember that all eligibility requirements for SSI must be met, with the exception of the Income and Resources Test, for a PASS to be used in establishing SSI cash payments. One of the criteria to be met is the SSA's definition of disability that says that individuals must not be working or if working, they must be earning under the SGA amount.

 

Wages that are excluded under a PASS cannot be deducted from gross wages to meet the SGA criteria. However, if individuals establish a PASS to meet the Income and Resources Test, the PASS expense can simultaneously be computed as an IRWE (assuming it meets IRWE criteria) to reduce wages for the SGA/medical disability determination. Only during the determination of SSI eligibility may the same expense be counted as an IRWE and PASS simultaneously. Once individuals meet both the SGA and Income and Resources Test, the actual amount of their cash benefit is computed. In the computation, expenses must be considered either as a PASS or an IRWE.

 

The PASS Specialist and ESR will play a vital role in the PASS application and review process. Each PASS Specialist and ESR are accessible via a 1-800 phone line and the customer can communicate directly with the PASS Specialist or ESR throughout the entire process. Specifically, "before denying a PASS on the basis that it is not a viable means of achieving the goal, SSA will contact the PASS Applicant, explain why the plan is not viable, and discuss with the applicant modifications that would make the plan viable."



Starting a Business Under a PASS
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If a person is considering submitting a PASS with a work goal of self-employment, it must include a detailed business plan. The plan may require securing concurrence by more knowledgeable third parties as to the feasibility of the business in terms of the person's ability to conduct the business and ability of the business to be successful. For someone beginning a business, the start-up costs include the expenses for the first 18 months or longer, if necessary for business operation.

 

Some possible third party reviewers may include:

 

* the individual's physician;

* vocational counselors;

* small business administration;

* local departments of employment and training;

* local chambers of commerce;

* local banks;

* appropriate staff at local colleges.

 

Components of a Business Plan
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The business plan must include the following components (not an exhaustive list):

 

* Business name, address, owner

* Business form

* Description of the principal activity of the business, including a description of the product and/or service to be provided

* Explanation of specific objectives of the business along with timetables for establishing the business and attaining the stated objectives

* Explanation as to why business should succeed and unique features

* A description of target market and audience demographics, and competition

* A description of the mechanism for pricing the product/services as well as a description of production and quality control

* A description of the financial plan, including any loans

* Advertising plan

* A list of personnel and their roles/qualifications

 

Calculating a PASS
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Income set aside in a PASS affects the amount of SSI cash benefits received by reducing the amount of total countable income. Total countable income includes earned income and unearned income. In determining individuals' monthly SSI checks, claims representatives compute the amount of the total countable income and subtract this amount from the FBR.

 

EXAMPLE: Effect of PASS on Unearned and Earned Income

John receives $220 in Child Disability Benefits and $462 in gross monthly earnings. As an individual with earned and unearned income, his total countable income would be calculated as follows.

 

$220 Unearned Income

Subtract $20 General Income Exclusion (GIE)

Equals $200 Countable Unearned Income

 

$462 Gross Earned Income

Subtract $0 Student-Earned Income Exclusion

Equals $462 Remainder

Subtract $0 GIE if not used above

Equals $462 Remainder

Subtract $65 Earned Income Exclusion

Equals $397 Remainder

Subtract $0 Impair. Related Work Exp.

Equals $397 Remainder

Divided by 2

Equals $198.50 Remainder

Subtract $0 Work Expenses if Blind

Equals $198.50 Total Countable Earned Income

 

$200 Total Countable Unearned Income

Plus $198.50 Total Countable Earned Income

Equals $398.50 Countable Income

Subtract $0 PASS Deduction

Equals $398.50 Total Countable Income

 

$564 Base SSI Rate

Subtract $398.50 Total Countable Income

Equals $165.50 SSI Payment

 

Earned and unearned income set aside in a PASS is subtracted from the individual's total countable income, thus increasing the amount of the SSI payment received. In the previous example, for instance, without a PASS John would receive an SSI payment of $165.50. If a PASS were established to purchase job coach support services at $150 a month, for a work goal increase independence in the job site, the effect on the SSI payment is as follows:

 

EXAMPLE: Effect of PASS on Unearned and Earned Income

 

$220 Unearned Income

Subtract $20 General Income Exclusion (GIE)

Equals $200 Countable Unearned Income

 

$462 Gross Earned Income

Subtract $0 Student-Earned Income Exclusion

Equals $462 Remainder

Subtract $0 GIE if not used above

Equals $462 Remainder

Subtract $65 Earned Income Exclusion

Equals $397 Remainder

Subtract $0 Impair. Related Work Exp.

Equals $397 Remainder

Divided by 2

Equals $198.50 Remainder

Subtract $0 Work Expenses if Blind

Equals $198.50 Total Countable Earned Income

 

$200 Total Countable Unearned Income

Plus $198.50 Total Countable Earned Income

Equals $398.50 Countable Income

Subtract $150 PASS Deduction

Equals $248.50 Total Countable Income

 

$564 Base SSI Rate

Subtract $248.50 Total Countable Income

Equals $315.50 SSI Payment

 

WORKSHEET: Effect of PASS on Unearned and Earned Income

Mary receives $200 in SSDAC and $600 in gross monthly earnings. As an individual with a $175 PASS deduction, supporting her work goal, calculate how her payment is affected.

 

Unearned Income

Subtract $20 General Income Exclusion (GIE)

Equals Countable Unearned Income

 

Gross Earned Income

Subtract Student-Earned Income Exclusion

Equals Remainder

Subtract GIE if not used above

Equals Remainder

Subtract Earned Income Exclusion

Equals Remainder

Subtract Impair. Related Work Exp.

Equals Remainder

Divided by 2

Equals Remainder

Subtract Work Expenses if Blind

Equals Total Countable Earned Income

 

Total Countable Unearned Income

Plus Total Countable Earned Income

Equals Countable Income

Subtract PASS Deduction

Equals Total Countable Income

 

Base SSI Rate

Subtract Total Countable Income

Equals SSI Payment



Two Factors Affecting PASS and SSI Check Amount
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It is important to note that PASS will not always result in individuals recouping 100 percent of the dollar amount they are expending in a PASS. To be insured that the increase in the SSI check is equal to the amount spent in the PASS, the following two conditions must exist:

 

* The total countable income is equal to, or less than, the FBR of; (more if State supplement involved); and,

* The amount set aside in the PASS does not exceed the total countable income.

 

Example: Expense Exceeds FBR

The following is an example of a PASS calculated for an individual whose total countable income is greater that the FBR. Michael earns $450 in wages a month and receives a Social Security check of $450 (still in his TWP). If Michael were to set aside the full amount of his total countable income in a PASS to cover job coaching follow-along services, to increase his work productivity, his monthly SSI payment would be adjusted as follows:

 

$450 Unearned Income

Subtract $20 General Income Exclusion (GIE)

Equals $430 Countable Unearned Income

 

$450 Gross Earned Income

Subtract $0 Student-Earned Income Exclusion

Equals $450 Remainder

Subtract $0 GIE if not used above

Equals $450 Remainder

Subtract $65 Earned Income Exclusion

Equals $385 Remainder

Subtract $0 Impair. Related Work Exp.

Equals $385 Remainder

Divided by 2

Equals $192.50 Remainder

Subtract $0 Work Expenses if Blind

Equals $192.50 Total Countable Earned Income

 

$430 Total Countable Unearned Income

Plus $192.50 Total Countable Earned Income

Equals $622.50 Countable Income

Subtract $622.50 PASS Deduction

Equals $0 Total Countable Income

 

$564 Base SSI Rate

Subtract $0 Total Countable Income

Equals $564 SSI Payment

 

Worksheet: PASS Comparison

 

While Michael will begin to receive an SSI check of $564 his monthly PASS expense will be $622.50. A comparison chart of his monthly finances with and without a PASS follows. Use the scenario in Example 13 and calculate Michael's possible benefits if he is not working, or working without a PASS.

 

Not Working

Income

SSI

Social Security

Earnings

Total Income

Expenses

Job Coaching

Total Expenses

Income

Minus Expenses

Total Income

 

Working Without PASS

SSI

Social Security

Earnings

Total Income

Expenses

Job Coaching

Total Expenses

Income

Minus Expenses

Total Income

 

Working with PASS

SSI $564

Social Security $450

Earnings $450

Total Income $1,464

Expenses

Job Coaching $622.50

Total Expenses $622.50

Income $1,464

Minus Expenses $622.50

Total Income $841.50

 

Michael will pay for his PASS expenses with the Social Security payments or his earnings. In this example, Michael recoups $564 of his $622.50 PASS expenditures. Because his monthly net income is being decreased by this amount, Michael must pay for the remaining $58.50 of his PASS expense. (The maximum dollar amount of federal SSI cash payment that can be received on a monthly basis is $564. This figure represents the maximum dollar amount (less state supplement) that individuals can recoup through SSI for goods and services paid for under a PASS. As a result, all persons with Total Countable Income over the combined amount will pay the difference out of their pocket, unless eligible for State supplement.)

 

Example: Expense Exceeds Total Countable Income

The following is an example of an individual who is setting aside more than her total countable income in a PASS. Mary earns $500 in wages a month and has no unearned income. Her total countable income is $207.50 prior to setting aside $350 a month in wages for a PASS expense associated with her work goal.

 

$0 Unearned Income

Subtract $20 General Income Exclusion (GIE)

Equals $0 Countable Unearned Income

 

$500 Gross Earned Income

Subtract $0 Student-Earned Income Exclusion

Equals $500 Remainder

Subtract $20 GIE if not used above

Equals $480 Remainder

Subtract $65 Earned Income Exclusion

Equals $415 Remainder

Subtract $0 Impair. Related Work Exp.

Equals $415 Remainder

Divided by 2

Equals $207.50 Remainder

Subtract $0 Work Expenses if Blind

Equals $207.50 Total Countable Earned Income

 

$0 Total Countable Unearned Income

Plus $207.50 Total Countable Earned Income

Equals $207.50 Countable Income

Subtract $350 PASS Deduction

Equals $0 Total Countable Income

 

$564 Base SSI Rate

Subtract $0 Total Countable Income

Equals $564 SSI Payment

 

As Mary has no countable income she begins to receive an SSI check of $564. However, while Mary's SSI check has increased by $207.50, her new PASS expense is $350. Her monthly finances with and without a PASS are as follows:

 

Not Working

Income

SSI $564

Social Security $0

Earnings $0

Total Income $564

Expenses

Job Coaching $0

Total Expenses $0

Income $564

Minus Expenses $0

Total Income $564

 

Working Without PASS

SSI $356.50

Social Security $0

Earnings $500

Total Income $856.50

Expenses

Job Coaching $350

Total Expenses $350

Income $856.50

Minus Expenses $350

Total Income $506.50

 

Working with PASS

SSI $564

Social Security $0

Earnings $500

Total Income $1,064

Expenses

Job Coaching $350

Total Expenses $350

Income $1,064

Minus Expenses $350

Total Income $714

 

Prior to establishing a PASS, Mary was receiving SSI payments in the amount of $356.50. Mary is therefore capable of increasing her payment by $207.50 ($564.00 -$356.50). Mary will pay for her PASS expenses using her earnings. She needs the SSI to pay for living expenses.

 

WORKSHEET: PASS Exceeds FBR and Total Countable Income

The following is an example of a PASS calculated for an individual whose total countable income is greater than the FBR. Brett earns $495 in wages a month and receives a Social Security check of $400 (still in his TWP). Set aside $695 of Michael's countable income in a PASS to cover job-coaching services.

 

Unearned Income

Subtract $20 General Income Exclusion (GIE)

Equals Countable Unearned Income

 

Gross Earned Income

Subtract Student-Earned Income Exclusion

Equals Remainder

Subtract GIE if not used above

Equals Remainder

Subtract Earned Income Exclusion

Equals Remainder

Subtract Impair. Related Work Exp.

Equals Remainder

Divided by 2

Equals Remainder

Subtract Work Expenses if Blind

Equals Total Countable Earned Income

 

Total Countable Unearned Income

Plus Total Countable Earned Income

Equals Countable Income

Subtract PASS Deduction

Equals Total Countable Income

 

Base SSI Rate

Subtract Total Countable Income

Equals SSI Payment



Effect of the One-Third Reduction Rule (Full In-Kind Support)
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In-kind support and maintenance is unearned income in the form of food, clothing, or shelter that is given to an eligible individual or is received because someone else pays for it. Whether someone else pays a living expense in full or just in part has a bearing on the amount of SSI cash benefits individuals receive. Individuals who live in someone else's household and receive both food and shelter and do not pay their pro rata share of the household expenses are subject to the full one-third reduction of their SSI benefits. This is referred to as the Value of the One-Third Reduction (VTR). Individuals falling into this category will have their SSI cash benefit reduced by one-third of the amount of the FBR. This reduction comes right off the top of their monthly benefit checks. The maximum amount of SSI that can be received by an individual who has a full in-kind support reduction is $376 ($564 - $188). A PASS will not help these individuals to increase their benefit to $564 (the SSI maximum benefit).) The one-third reduction will be taken off the top of their SSI cash benefit, regardless of whether or not a PASS is used. An example follows:

 

Jack receives SSI and will soon begin a new job earning $595 a month. Because Jack has a full in-kind support reduction, he currently receives $376 in SSI each month. Jack will need job coach support for his new job and intends to pay $405.66 a month for these services under a PASS. The following calculation shows how his SSI check will be affected given (1) his new earnings, (2) PASS expense, and (3) in-kind support reduction. Jack is eligible to receive $376 in SSI and $595 in wages each month. Therefore Jack pays $405.66 from his $595 wages for the job coaching services he needs under his work goal, and he recovers $255 of this in his SSI check (the amount he would not receive of SSI without a PASS).

 

EXAMPLE: Calculating PASS with In-kind Support (VTR)

(Earned Income Only)

 

$0 Unearned Income

Subtract $20 General Income Exclusion (GIE)

Equals $0 Countable Unearned Income

 

$595 Gross Earned Income

Subtract $0 Student-Earned Income Exclusion

Equals $595 Remainder

Subtract $20 GIE if not used above

Equals $575 Remainder

Subtract $65 Earned Income Exclusion

Equals $510 Remainder

Subtract $0 Impair. Related Work Exp.

Equals $510 Remainder

Divided by 2

Equals $255 Remainder

Subtract $0 Work Expenses if Blind

Equals $255 Total Countable Earned Income

 

$0 Total Countable Unearned Income

Plus $255 Total Countable Earned Income

Equals $255 Countable Income

Subtract $405 PASS Deduction

Equals $0 Total Countable Income

 

$376 Base SSI Rate

Subtract $0 Total Countable Income

Equals $376 SSI Payment



The Presumed Maximum Value Rule (Partial In-Kind Support)
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When the VTR rule does not apply ISM is determined using the Presumed Maximum Value Rule (PMV). For example, the PMV is used if the eligible individual has ownership interest or rental liability, separately purchases, or consumes food, gets only ISM, etc. SSA presumes that the maximum value of the support and maintenance an individual gets is no more than $208. They arrive at this figure by adding $20 to the one-third-reduction amount of $188. After subtracting a $20 general exclusion from the PMV, the reduction in the SSI check is $188. But, if the actual value of the ISM is less than the PMV, only the actual value is counted as ISM. For example, if a third party pays the household's electric bill which was $100, only $100 is counted as ISM and the $100 is divided equally among all the household members. If the household has four members, only $25 of ISM is counted for the SSI eligible individual. Individuals who have a partial in-kind support reduction and initiate a PASS are able to subtract the PASS expense from the PMV, making it possible to increase their SSI cash benefit amount to $564 (the maximum SSI payment amount). For individuals with a full in-kind support reduction (VTR) who are initiating a PASS, it may be in their best interest to begin contributing to the food and/or shelter expenses. Doing this may help them to recoup a greater amount of their PASS expenses through an increase in their SSI. The following example illustrates the benefits of taking this action.

 

If Jack chooses to begin paying for his monthly food expenses, he will have a PMV in-kind support reduction.

 

EXAMPLE: Calculating PASS with In-kind Support (PMV)

(Earned Income Only)

 

$208 Unearned Income

Subtract $20 General Income Exclusion (GIE)

Equals $188 Countable Unearned Income

 

$595 Gross Earned Income

Subtract $0 Student-Earned Income Exclusion

Equals $595 Remainder

Subtract $0 GIE if not used above

Equals $595 Remainder

Subtract $65 Earned Income Exclusion

Equals $530 Remainder

Subtract $0 Impair. Related Work Exp.

Equals $530 Remainder

Divided by 2

Equals $265 Remainder

Subtract $0 Work Expenses if Blind

Equals $265 Total Countable Earned Income

 

$188 Total Countable Unearned Income

Plus $265 Total Countable Earned Income

Equals $453 Countable Income

Subtract $405.66 PASS Deduction

Equals $47.34 Total Countable Income

 

$564 Base SSI Rate

Subtract $47.34 Total Countable Income

Equals $516.66 SSI Payment



Deciding Between PASS and IRWE
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Many items or services, which are allowable under a PASS, may also meet criteria for exclusion as an IRWE. However, items or services may be excluded only under one of these two work incentive provisions at a time, when computing the amount of the SSI cash benefit to be received! It is not possible to set aside earnings under a PASS to purchase job coach services and at the same time subtract the expense of these services from monthly gross wages as an IRWE. At any given time, the expense of job coach services may be either a PASS or an IRWE for SSI cash benefit computation purposes. However, if the PASS goal has already been attained, it must be computed as an IRWE.

 

When items or services meet criteria for both PASS and IRWE, it is better to establish a PASS because of the order in which these two exclusions are applied in the SSI benefit computation. An example of a vocational goal-related service calculated as an IRWE first and then as a PASS may best demonstrate the differences between the two work incentives. Two examples follow:

 

Example: Calculating PASS and IRWE

John must purchase job-coaching services to assist in his initial job training. The expense is $100 per month. This expense meets criteria for exclusion under both IRWE and PASS. John receives $456.50 a month in SSI and earns $300 in gross wages. His current monthly income is $756.50 from these sources. Once the expense is paid for, over and above his SSI check, John's spendable income is $656.50 without a PASS or IRWE. Below shows the impact of both PASS and IRWE on his usable income.

 

IRWE

 

$300 Gross wages

Subtract $85 Exclusions

Equals $215

Subtract $100 Cost of IRWE

Equals $115 Countable earned income

Divided /2

Equals $57.50 Total countable income

 

$564 Base SSI Rate

Subtract $57.50

Equals $506.50 SSI check

 

$300 Wages

Plus $506.50 SSI payment

Equals $806.50 Monthly income

Subtract $100 Cost of IRWE

Equals $706.50 Monthly spendable income

 

PASS

 

$300 Gross wages

Subtract $85 Exclusions

Equals $215

Divided /2

Equals $107.50 Total countable income

Subtract $100 PASS expense

Equals $7.50 Revised countable income

 

$564 Base SSI Rate

Subtract $7.50 Total countable income

Equals $556.50 SSI check

 

$300 Wages

Plus $556.50 SSI payment

Equals $856.50 Monthly income

Subtract $100 PASS expense

Equals $756.50 Monthly spendable income

 

The difference in the methods of calculating IRWE and PASS results in a 100 percent reimbursement of job coaching expense under PASS, and only a 50 percent reimbursement of the same expense under IRWE. As illustrated, it would be better for John to establish a PASS to pay for this expense. Some items established as a PASS may be switched to IRWE when the PASS exclusion is no longer available. Remember that it is usually better to use the PASS work incentive instead of the IRWE. Both options should be investigated with the assistance of the local SSA office to determine the best option for each situation.



Concurrent PASS and IRWE
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It is permissible to have a PASS for one or more expenses and at the same time have an IRWE for other work-related expenses not covered by the PASS. The following case study and example illustrate the benefit of having a concurrent PASS and IRWE.

 

EXAMPLE:

Barbara is an SSI recipient with a disability. She is participating in a job-training program for which she is paid $400 monthly. She is currently excluding $50 per month (her contribution toward the cost of her physical therapy) as an IRWE. She decides to purchase a specifically modified van to allow her to continue the program pursue her work goal and secure employment. The van payment is determined to be excludable under a PASS at $350 per month. Barbara also receives $225 monthly in Social Security benefits. Without an IRWE or a PASS Barbara would qualify for an SSI payment of $191.50.

 

$225 Unearned Income

Subtract $20 General Income Exclusion (GIE)

Equals $205 Countable Unearned Income

 

$400 Gross Earned Income

Subtract $0 Student-Earned Income Exclusion

Equals $400 Remainder

Subtract $0 GIE if not used above

Equals $400 Remainder

Subtract $65 Earned Income Exclusion

Equals $335 Remainder

Subtract $0 Impair. Related Work Exp.

Equals $335 Remainder

Divided by 2

Equals $167.50 Remainder

Subtract $0 Work Expenses if Blind

Equals $167.50 Total Countable Earned Income

 

$205 Total Countable Unearned Income

Plus $167.50 Total Countable Earned Income

Equals $372.50 Countable Income

Subtract $0 PASS Deduction

Equals $372.50 Total Countable Income

 

$564 Base SSI Rate

Subtract $372.50 Total Countable Income

Equals $191.50 SSI Payment

 

EXAMPLE: Calculating Concurrent PASS and IRWE

Using both the $350 PASS expense and IRWE enables Barbara to begin receiving an SSI payment of $564.

 

$225 Unearned Income

Subtract $20 General Income Exclusion (GIE)

Equals $205 Countable Unearned Income

 

$400 Gross Earned Income

Subtract $0 Student-Earned Income Exclusion

Equals $400 Remainder

Subtract $0 GIE if not used above

Equals $400 Remainder

Subtract $65 Earned Income Exclusion

Equals $335 Remainder

Subtract $50 Impair. Related Work Exp.

Equals $285 Remainder

Divided by 2 Equals

Equals $142.50 Remainder

Subtract $0 Work Expenses if Blind

Equals $142.50 Total Countable Earned Income

 

$205 Total Countable Unearned Income

Plus $142.50 Total Countable Earned Income

Equals $347.50 Countable Income

Subtract $350 PASS Deduction

Equals $0 Total Countable Income

 

$564 Base SSI Rate

Subtract $0 Total Countable Income

Equals $564 SSI Payment



PASS and Social Security
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Remember that the PASS work incentive applies the SSI program and has no effect on the Social Security benefits received. However, some expenses paid for under a PASS also meet the criteria for exclusion as an IRWE. (When expenses meet the criteria for PASS and IRWE, the expense can be counted as a PASS for SSI payment calculation and also computed as an IRWE for on-going SGA determinations for Social Security.) The following example illustrates how this can be financially beneficial to individuals receiving both SSI and Social Security.

 

Mark currently receives both SSI and $300 in Social Security. During previous employment he completed his TWP for Social Security. He is in his EPE for Social Security at the present time. Mark recently started a new job and is earning $850 monthly. He is in need of job coach support services that will cost $300 a monthly which will assist him in preparing for a better paying job inadvertently offsetting the loss of all his benefits. If Mark does not use a work incentive to pay for this service he will lose his Social Security check immediately. His Social Security will stop with this new job because his earnings are over the SGA level. This is illustrated in the following calculation:

 

EXAMPLE: Example Without PASS Applied

 

$0 Unearned Income

Subtract $20 General Income Exclusion (GIE)

Equals $0 Countable Unearned Income

 

$850 Gross Earned Income

Subtract $0 Student-Earned Income Exclusion

Equals $850 Remainder

Subtract $20 GIE if not used above

Equals $830 Remainder

Subtract $65 Earned Income Exclusion

Equals $765 Remainder

Subtract $0 Impair. Related Work Exp.

Equals $765 Remainder

Divided by 2 Equals

Equals $382.50 Remainder

Subtract $0 Work Expenses if Blind

Equals $382.50 Total Countable Earned Income

 

$0 Total Countable Unearned Income

Plus $382.50 Total Countable Earned Income

Equals $382.50 Countable Income

Subtract $0 PASS Deduction

Equals $382.50 Total Countable Income

 

$564 Base SSI Rate

Subtract $382.50 Total Countable Income

Equals $181.50 SSI Payment

 

Because Mark will lose his Social Security, his spendable income will consist only of his $850 earnings and $181.50 SSI check. In addition, he is still faced with the $300 job coach expense.

 

If Mark decides to establish a PASS to pay for the job coaching expense as part of a work goal, he will be able to retain $191.50 in SSI. (See the following calculation). Because job coaching also meets criteria for the IRWE exclusion, this expense will be deducted from his gross earnings before the SGA determination is made for Social Security. His countable earnings are now $550 ($850 - $300). Since his countable income is below the SGA level, he will maintain his $300 Social Security payment as well.

 

EXAMPLE: SSI Example With PASS Applied

 

$300 Unearned Income

Subtract $20 General Income Exclusion (GIE)

Equals $280 Countable Unearned Income

 

$850 Gross Earned Income

Subtract $0 Student-Earned Income Exclusion

Equals $850 Remainder

Subtract $0 GIE if not used above

Equals $850 Remainder

Subtract $65 Earned Income Exclusion

Equals $785 Remainder

Subtract $0 Impair. Related Work Exp.

Equals $785 Remainder

Divided by 2 Equals

Equals $392.50 Remainder

Subtract $0 Work Expenses if Blind

Equals $392.50 Total Countable Earned Income

 

$280 Total Countable Unearned Income

Plus $392.50 Total Countable Earned Income

Equals $672.50 Countable Income

Subtract $300 PASS Deduction

Equals $372.50 Total Countable Income

 

$564 Base SSI Rate

Subtract $372.50 Total Countable Income

Equals $191.50 SSI Payment

 

 Mark's spendable income using the work incentives is $1,341.50.

 

$850 Wages

Plus $300 Social Security

Plus $191.50 SSI

Equals $1,341.50 TOTAL INCOME

 

After Mark pays for his $300 PASS expense he will have $1,041.50 remaining.



Final Comments on PASS
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Following are some additional highlights to the PASS Program outlined in Carolyn Colvin's statement on December 1, 1997:

 

* Anyone whose PASS was terminated or denied after March 1996 will be contacted, informed of the 12/1/97 changes to the Program, and invited to submit a new PASS.

* PASS reviews will continue to include current stewardship requirements, but will be more proactive and supportive. The PASS Specialists will augment these reviews with periodic telephone calls. These calls will help the PASS Specialist and the individual identify and remedy actual or potential problems before they affect the integrity of the PASS, and should improve chances for successful completion.

* SSA will place emphasis on flexibility in amending a PASS retroactively when changes have occurred that do not compromise the integrity of the plan.

 

PASS Case Study
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Sharon is 19, a student in school, due to graduate this spring. She is excited about the possibility of going to college and eventually being on her own. Sharon has cerebral palsy, uses a motorized wheelchair, and has use of her arms and hands but has very little strength in them, so needs assistance to transfer, to finish dressing, etc. She is a good student and is very motivated to keep learning.

 

Sharon's goal is to become an elementary school teacher, and she wants to attend Peabody Teachers' College, a private school about 30 miles from her home. She has an open VR file, and they have agreed to pay about half of the cost of tuition and books ($2,700/semester; equivalent to a state university), but she must apply for grants first.

 

Sharon would like to live on campus, and she would like to get a van and adapt it for her own use. She took a driver's evaluation, and they report that she is a good candidate for driver's education class. She has priced a van and it would cost nearly $20,000. VR is open to considering paying for modifications, if she has the van.

 

Sharon currently lives with her retired parents, and she receives $66 (VTR) SSI and $330 SSDI. She has saved no money, and her parents are not in a position to help her very much with costs of college.

 

Directions: Divide into groups of 4-5. Select a group facilitator and reporter. Read through the case study and answer the following questions together. Report out as requested.

 

1. List three factors that might make Sharon a likely candidate for a PASS.

2. Given Sharon's vocational goal, list some possible milestones to accomplish it.

3. Brainstorm a possible list of monetary resources for each expense associated with reaching the goal (as best you can anticipate them).

4. What might be some decisions that Sharon would need to make if she pursues using a PASS as a major funding source for accomplishing her goal?

 

PASS Format
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Following is a PASS format and directions prescribed by SSA.

 

Page 1 of Form SSA-545-BK (2/99)

 

PLAN FOR ACHIEVING SELF-SUPPORT Date Received________________________

 

In order to minimize recontacts or processing delays, please complete all questions and provide thorough explanations where requested. If you need additional space to answer any questions use the Remarks section or a separate sheet of paper.

 

Name_____________________________________SSN_______________________________

 

PART I - YOUR WORK GOAL

A. What is your goal? (Show the specific job you expect to have at the end of the plan. If you do not yet have a specific work goal and will be working with a vocational professional to find a suitable job match, show "VR Evaluation," be sure to complete Part II, question F on page 4.

________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________

 

If your goal involves supported employment, show the number of hours of job coaching you will receive when you begin working __________ per week/month (circle one).

 

Show the number of hours of job coaching you expect to receive after the plan is completed.

__________ per week/month (circle one).

B. Describe the duties you expect to perform in this job. Be as specific as possible (standing, walking, sitting, lifting stooping, bending, contact with the public, writing reports/documents, etc.)

________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________

C. How did you decide on this work goal and what makes this job attractive to you?

________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________

D. If your work goal does not involve self-employment, how much do you expect to earn each month (gross) after your plan is completed? $__________/month

 

End of Page 1 Form SSA-545-BK (2/99)

 

E. If your work goal involves self-employment, explain why working for yourself will make you more self-supporting than working for someone else.

________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________

 

NOTE: If you plan to start your own business, attach a detailed business plan. At a minimum the business plan must include the type of business; products or services to be offered by your business; a description of the market for the business; the advertising plan; technical assistance needed; tools, supplies, and equipment needed; and a profit-loss projection for the duration of the PASS and at least one year beyond its completion. Also include a description of how you intend to make this business succeed.

F. Did someone help you prepare this plan? ___ YES ___ NO If "NO," skip to G.

If "YES," show the name, address and telephone number of that individual or organization.

________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________

 

May we contact them if we need additional information about your plan? ___ YES ___ NO

 

Do you want us to send them a copy of our decision on your plan? ___ YES ___ NO

 

Are they charging you a fee for this service? ___ YES ___ NO

If "YES," how much are they charging? ____________________________

G. Have you ever submitted a Plan for Achieving Self Support (PASS) to Social Security? ___ YES ___ NO

If "NO," skip to Part II.

If "YES," complete the following:

 

Was a PASS ever approved for you? ___ YES ___ NO If "NO," skip to Part II.

If "YES," complete the following:

 

When was your most recent plan approved (month/year)?__________________________

What was your work goal in that plan?__________________________________________

 

Did you complete that PASS? ___ YES ___ NO

If "NO," why weren't you able to complete it? __________________________________

________________________________________________________________________________

________________________________________________________________________________

 

If "YES," why weren't you able to become self-supporting?_______________________

________________________________________________________________________________

 

Why do you believe that this new plan you are requesting will help you go to work?

__________________________________________________________________________

 

End Page 2 Form SSA-545-BK (2/99)

 

PART II - MEDICAL/VOCATIONAL BACKGROUND

 

A. What are your disabling illnesses, injuries, or conditions?_______________

________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________

B. Describe any limitations you have because of your disability (e.g., limited amount of standing or lifting, stooping, bending, or walking; difficulty concentrating; unable to work with other people, difficulty handling stress, etc.) Be specific.

_____________________________________________________________

_____________________________________________________________

_____________________________________________________________

_____________________________________________________________

_____________________________________________________________

_____________________________________________________________

_____________________________________________________________

In light of the limitations you described, how will you carry out the duties of your work goal?

________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________

C. List the jobs you have had most often in the past few years. Also list any jobs, including volunteer work, which are similar to your work goal or which provided you with skills that may help you perform the work goal. List the dates you worked in these jobs. Identify periods of self-employment.If you were in the Army, list your Military Occupational Specialty (MOS) code; for the Air Force, listyour Air Force Specialty (AFSC) code; and for the Navy, Marine Corps, and Coast Guard, list your RATE.

 

Job Title

Type of Business

Dates Worked

 

End of Page 3 Form SSA-545-BK (2/99)

 

D. Circle the highest grade of school completed.

0 1 2 3 4 5 6 7 8 9 10 11 12 GED or High School Equivalency

 

College: 1 2 3 4 or more

 

1. Were you awarded a college or postgraduate degree? ___ YES ___ NO

When did you graduate?_________________________

What type of degree did you receive? (B.A., B.S., M.B.A., etc.) _________

In what field of study?__________________________________________________

 

2. Did you attend special education classes? ___ YES ___ NO If "NO," skip to E.

If "YES," complete the following:

 

Name of school __________________________________________________________

Address___________________________________________________________________

Dates attended: From _____________________ To ______________________

Type of program__________________________________________________________

 

E. Have you completed any type of special job training, trade or vocational school? ___ YES ___ NO

If "NO," skip to F.

If "YES," complete the following:

 

Type of training _________________________________________________________

Date completed ___________________________________________________________

Did you receive a certificate or license? ___ YES ___ NO If "NO," skip to F.

If "YES," what kind of certificate or license?

__________________________________________________________________________

__________________________________________________________________________

 

F. Have you ever had or expect to have a vocational evaluation or an Individualized Written Rehabilitation Plan (IWRP) or an Individualized Employment Plan (IEP)? ___ YES ___ NO

 

If "YES," attach a copy of the evaluation and skip to Part III (page 5). If you cannot attached a copy, complete the following:

 

When were you evaluated or when do you expect to be evaluated or when was the IWRP or IEP done or when do you expect it to be done? ________________

 

Show the name, address, and phone number of the person or organization who evaluated you or will evaluate you or who prepared the IRWP or IEP or will prepare the IWRP or IEP.

__________________________________________________________________________

 

End of Page 4 Form SSA-545-BK (2/99)

 

Part III - Your Plan

 

I want my Plan to begin ___________________________________________(month/year)

and my Plan to end_________________________________________________(month/year)

 

List the steps, in sequence that you will take to reach this goal. Be as specific as possible. If you will be attending school, show the courses you will study each quarter/semester. Include the final steps to find a job one you have obtained the tools, education, services, etc., that you need.

 

Step:

Beginning Date:

Completion Date:

________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

 

End Page 5 Form SSA-545-BK (2/99)

 

PART IV - EXPENSES

 

A. If you propose to purchase, lease, or rent a vehicle, please provide the following additional information:

1. Explain why less expensive forms of transportation (e.g., public transportation, cabs) will not allow you to reach your work goal.

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

2. Do you currently have a valid driver's license? ___ YES ___ NO

If "YES," skip to 3.

If "NO," complete the following:

 

Who will drive the vehicle?______________________________________________

How will it be used to help you with your work goal?_____________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

3. If you are proposing the purchase a vehicle, explain why renting or leasing are not sufficient.

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

4. Explain why you chose the particular vehicle. (Note: the purchase of the vehicle should be listed as one of the steps in Part III.)

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

 

End of Page 6 Form SSA-545-BK (2/99)

 

B. If you propose to purchase computer equipment or other expensive equipment, please explain why a less expensive alternative (e.g., rental or a computer or purchase of a less expensive model) will not allow you to reach your goal. Explain why you need the capabilities of the particular computer/equipment you identified. Also, if you attend (or will attend) a school with a computer lab for student use, explain why use of that facility is not sufficient to meet your needs.

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

 

C. Other than the items identified in A or B above, list the items or services you are buying or renting or will need to buy or rent in order to reach your work goal. Be as specific as possible. If schooling is an item, list tuition, fees, books, etc. as separate items. List the cost for the entire length of time you will be in school. Where applicable, include brand and model number or the item. (Do not include expenses you were paying prior to the beginning of your plan; only additional expenses incurred because of your plan can be approved.)

 

NOTE: Be sure that Part III shows when you will purchase these items or services or training.

 

1. Item/service training _________________________Cost $ _____________

 

Vendor provider ___________________________________________________

 

How will this help you reach your work goal? ______________________

___________________________________________________________________

 

How did you determine the cost? ___________________________________

___________________________________________________________________

 

Why wouldn't something less expensive meet your needs? ____________

___________________________________________________________________

___________________________________________________________________

2. Item/service training ________________________Cost $ ______________

 

Vendor provider ___________________________________________________

 

How will this help you reach your work goal? _______________________

____________________________________________________________________

 

How did you determine the cost? ____________________________________

____________________________________________________________________

 

Why wouldn't something less expensive meet your needs? _____________

____________________________________________________________________

____________________________________________________________________

 

End of Page 7 Form SSA-545-BK (2/99)

 

3. Item/service training _________________________Cost $ ______________

 

Vendor provider ___________________________________________________

 

How will this help you reach your work goal? ______________________

___________________________________________________________________

 

How did you determine the cost? ___________________________________

___________________________________________________________________

 

Why wouldn't something less expensive meet your needs? ____________

___________________________________________________________________

___________________________________________________________________

4. Item/service training _________________________Cost $ _____________

 

Vendor provider ___________________________________________________

 

How will this help you reach your work goal? ______________________

___________________________________________________________________

 

How did you determine the cost? ___________________________________

___________________________________________________________________

 

Why wouldn't something less expensive meet your needs? ____________

___________________________________________________________________

___________________________________________________________________

5. Item/service training _________________________Cost $ _____________

 

Vendor provider ___________________________________________________

 

How will this help you reach your work goal? ______________________

___________________________________________________________________

 

How did you determine the cost? ___________________________________

___________________________________________________________________

 

Why wouldn't something less expensive meet your needs? ____________

___________________________________________________________________

___________________________________________________________________

 

End Page 8 Form SSA-545-BK (2/99)

 

D. If you indicated in Part II (page 4) that you have a college degree or specialized training, and your plan includes additional education or training, explain why the education/training you already received is not sufficient to allow you to be self-supporting. __________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

 

E. What are your current expenses each month (rent, food, utilities, phone, property taxes, homeowner's insurance automobile repair and maintenance, public transportation costs, clothes, laundry/dry cleaning, charity contributions, etc.)? $__________/month

 

If the amount of income you will have available for living expenses after making payments or saving money for your plan expenses is less than your current living expenses, explain how you will pay for your living expenses.

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

 

End Page 9 Form SSA-545-BK (2/99)

 

PART V - FUNDING FOR WORK GOAL

 

A. Do you plan to use any items you already own (e.g., equipment or property) to reach our work goal?

 

___ YES ___ NO

If "NO," skip to B.

If "YES," complete the following:

 

Item______________________________________________________________________

Value_____________________________________________________________________

How will this help you reach your work goal?______________________________

__________________________________________________________________________

 

Item______________________________________________________________________

Value_____________________________________________________________________

How will this help you reach your work goal?______________________________

__________________________________________________________________________

 

B. Have you saved any money to pay for the expenses listed on pages 6-8 in Part IV? (Include cash on hand or money in a bank account.) ___ YES ___ NO If "NO," skip to C.

 

C. Do you receive or expect to receive income other than SSI payments?

___ YES ___ NO

If "NO," skip to F.

If "YES," provide details as follows:

 

Type of Income

Amount

Frequency (Weekly, Monthly, Yearly)

 

D. How much of this income will you use each month to pay for the expenses listed in Part IV?

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

 

End of Page 10 Form SSA-545-BK (2/99)

 

E. Do you plan to save any or all of this money for a future purchase which is necessary to complete your goal? ___ YES ___ NO If "NO," skip to F.

If "YES," how will you keep the money separate from other money you have? (If you will keep the savings in a separate bank account, give the name and address of the bank and the account number.)

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

 

F. Will any other person or organization (e.g., Vocational Rehabilitation, school grants, Job Partnership Training Assistance (JTPA) pay for or reimburse you for any part of the expenses listed in Part IV or provide any other items or services you will need? ___ YES ___ NO If "NO," skip to Part VI.

 

Who will pay

Item/Service

Amount

When will the item/service be purchased

 

PART VI - REMARKS

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

 

PART VII -- AGREEMENT

 

If my plan is approved, I agree to:

___ Comply with all of the terms and conditions of the plan as approved by the

Social Security Administration (SSA);

___ Report any changes in my plan to SSA immediately

 

End of Page 11 Form SSA-545-BK (2/99)

 

___Keep records and receipts of all expenditures I make under the plan until asked to provide them to SSA.

___Use the income or resources set aside under the plan only to buy the items or services shown in the plan as approved by SSA.

 

I realize that if I do not comply with the terms of the plan or if I use the income or resources set aside under my plan for any other purpose, SSA will count the income or resources that were excluded and I may have to repay the additional SSI I received.

 

I also realize that SSA may not approve any expenditures for which I do not submit receipts or other proof of payment.

 

I know that anyone who makes or causes to be made a false statement or representation of material fact in an application for use in determining a right to payment under the Social Security Act commits a crime punishable under Federal Law and/or State Law. I affirm that all the information I have given on this form is true.

 

Signature ______________________________________Date___________________________

 

Address________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

 

Telephone:

Home___________________________________

 

Work___________________________________

 

End Page 12 Form SSA-545-BK (2/99)

 

PRIVACY ACT STATEMENT

 

The Social Security Administration is allowed to collect the information on this form under section 1631 (e) of the Social Security Act. We need this information to determine if we can approve your plan for achieving self-support. Giving us this information is voluntary. However, without it, we may not be able to approve your plan. Social Security will not use the information for any other purpose.

 

We would give out the facts on this form without your consent only in certain situations. For example, we give out this information if a Federal law requires us to or if your Congressional Representative or Senator needs the information to answer questions you ask them.

 

PAPERWORK REDUCTION ACT NOTICE AND TIME IT TAKES STATEMENT

 

The Paperwork Reduction Act of 1995 requires us to notify you that this information collection is in accordance with the clearance requirements of section 3507 of the Paperwork Reduction Act of 1995. We may not conduct or sponsor, and you are not required to respond to, a collection of information unless it displays a valid OMB control number. We estimate that it will take you about 120 minutes to complete this form. This includes the time it will take to read the instruction, gather the necessary facts and fill out the form.

 

End of Page 13 Form SSA-545-BK (2/99)

 

OUR RESPONSIBILITIES TO YOU

 

We received the plan for achieving self-support (PASS) on _____________________. Your plan will be processed by Social Security employees who are trained to work with PASS.

 

The PASS expert handling your case will work directly with you. He or she will look over the plan as soon as possible to see if there is a good chance that you can meet your work goal. The PASS expert will also make sure that the things you want to pay for are needed to achieve your work goal and are reasonably priced. If changes are needed, the PASS expert will discuss them with you.

 

Your may contact the PASS expert toll-free at 1-______________________________.

 

YOUR REPORTING AND RECORDKEEPING RESPONSIBILITIES

 

If we approve your plan, you must tell Social Security about any changes to your plan. You must tell us if:

 

Your medical condition improves.

You are unable to follow your plan.

You decide not to pursue your goal or decide to pursue a different goal.

You decide that your do not need to pay for any of the expenses you listed in your plan.

Someone else pays for any of your plan expenses.

You use the income or resources we exclude for a purpose other than the expense specified in your plan.

There are any other changes to your plan.

 

You must tell us about any of these things within 10 days following the month in which it happens. If you do not report any of these things, we may stop your plan.

 

You should also tell us if you decide that you need to pay for other expenses not listed in your plan in order to reach your goal. We may be able to change your plan or change the amount of income we exclude so you can pay for the additional expenses.

 

YOU MUST KEEP RECEIPTS OR CANCELLED CHECKS TO SHOW THAT EXPENSES YOU PAID FOR AS PART OF THE PLAN. You need to keep these receipts or cancelled checks until we contact you to find out if you are still following your plan. When we contact you, we will ask to see the receipts or cancelled checks. If you are not following the plan, you may have to pay back the some or all of the SSI you received.

 

End of Page 14 End of Form SSA-545-BK (2/99)



PASS Review Process
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Initial PASS applications will be reviewed for compliance with POMS (SI E00870.000).

 

Once an initial PASS application has been received by the field office, it will then be forwarded to a PASS specialist within a day for approval, modification, or denial. A PASS specialist will review the application using the "Initial PASS Checklist" below and will work directly with the PASS applicant to complete development of the PASS.



Exhibit 1 -- Initial PASS Checklist
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Initial PASS Checklist

I. Goal

A. Is the goal a specific occupation or "VR Evaluation?" ___Yes ___No

B. Does the individual have a reasonable chance of achieving the goal?

___Yes ___No

C. If successful, will the goal result in sufficient earned income to significantly reduce/eliminate SSI or eliminate Social Security?

___Yes ___No

NOTE: If A, B, or C are answered "No," the PASS must be modified (or denied if modification not appropriate).

 

D. Was a personal contact made with the individual to ensure an understanding of PASS purpose and rules?

___Yes ___No

 

E. Does the plan specify the total time necessary to reach the goal?

___Yes ___No

 

II. PASS Expenses

A. Are all expenses directly related to achieving the goal? ___Yes ___No

B. Have less expenses alternatives been considered? ___Yes ___No

C. Are all expenses reasonable? ___Yes ___No

D. Does the individual have sufficient income to pay PASS expenses and normal living expenses? ___Yes ___No

E. Are PASS funds being kept separate from other funds? ___Yes ___No

 

III. Third Party Involvement

A. If a PASS development fee was charged, does the plan provide details on:

1. the specific services provided ___Yes ___No

2. the number of hours spent by the third party on each service ___Yes ___No

3. the hourly rate charged by the third party ___Yes ___No

Is the hourly rate reasonable for the local area? ___Yes ___No

B. Is there a completed and signed SSA-3288 in file? ___Yes ___No

 

IV. Decision

A. Is the PASS signed? ___Yes ___No

B. If appropriate, was the individual given the opportunity to modify the PASS?

___Yes ___No

C. Have the proper notices been sent (including copies to a representative payee, an authorized representative or any other person/organization authorized by the individual to receive the notice)?

___Yes ___No

D. Has the income/resources exclusion been posted to the SSR? ___Yes ___No

E. Has the CG field been annotated for a resource exclusion? ___Yes ___No

F. Has a copy of all PASS material (i.e., plan, addenda, documentation and notice(s)) been placed in FO PASS file? ___Yes ___No

 

Once the review is completed, the PASS specialist will either request additional documentation from the applicant or release the approval or denial notice. Should a PASS application be denied, the applicant can request a redetermination by another PASS specialist.

 

Progress reviews will be conducted at intervals determined by the PASS specialist and at least every 12 months. Reviews will be done using the following "PASS Progress Review" along with periodic phone calls from cadre members to identify and remedy actual or potential problems before they affect the integrity of the PASS.

<

Exhibit 2 -- PASS Progress Review
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PASS Progress Review

I. Goal

A. Is the individual working in the job or business as specified in the plan?

___Yes ___No

If "Yes," skip to Part II.

B. Is the individual still following the plan as approved (i.e., has the person completed the milestones on time)? ___Yes ___No

C. Has the timeframe for completing the plan changed? ___Yes ___No

 

II. PASS Expenses A. Are all approved expenses paid? ___Yes ___No

B. Have the PASS funds been used only for approved expenses? ___Yes ___No

C. Have any of the expenditures been paid by another person or organization (other than a deemer)? ___Yes ___No

D. Has the person been reimbursed from any source for any of the expenditures?

___Yes ___No

E. Total amount excluded to date: $ __________

F. Total allowable expenditures to date: $ __________

G. If exclusion exceeds expenditures, are excess funds being kept separate from other funds? ___Yes ___No

H. Has there been any change in the individual's income or resources that requires a change in the PASS? ___Yes ___No

I. Is resumption of PASS after suspension an issue? ___Yes ___No

 

III. Decision

A. What is the status of the PASS?

1. Individual has reached work goal ___Yes ___No

If "Yes," skip to B.2.

2. Individual has abandoned plan ___Yes ___No

If "Yes," skip to B.1.

3. Individual is in compliance with plan or amendment ___Yes ___No

If "Yes," go to B.1.

If "No," go to B.2.

B. What is the result of the review?

1. Extend PASS ___Yes ___No

Continue with current plan ___Yes ___No

Continue only with amendment ___Yes ___No

PASS extended until _______________

2. Stop PASS ___Yes ___No

Suspension of plan ___Yes ___No

Termination of plan ___Yes ___No

PASS being stopped as of _______________

C. Have the proper notices been sent (including copies to a representative payee, an authorized representative, or any other person/organization authorized by the individual to receive the notice)?

___Yes ____No

D. Has the income exclusion been adjusted on the SSR? ___Yes ___No

E. If the PASS is being suspended or terminated, has a final accounting been done? ___Yes ___No



SSI / Social Security Comparison Chart
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SSI - Below Age 18

No Trial Work Period (TWP), Extended Period of Eligibility (EPE), or unsuccessful work attempt provisions)

SSI - Above Age 18

No Trial Work Period (TWP), Extended Period of Eligibility (EPE), or unsuccessful work attempt provisions)

Social Security - Above Age 18

TWP, EPE, and unsuccessful work attempt provisions provided to individuals who are blind or non-blind

 

SSI - Below Age 18

Credit for subsidy at initial eligibility determination

SSI - Below Age 18

Credit for subsidy at initial eligibility determination

Social Security - Above Age 18

Credit for subsidy

 

SSI - Below Age 18

Credit for Impairment-Related Work Expense (IRWE)

SSI - Above Age 18

Credit for Impairment-Related Work Expense (IRWE)

Social Security - Above Age 18

Credit for IRWE

 

SSI - Below Age 18

Credit for Blind-Work Expenses (BWE)

SSI - Above Age 18

Credit for Blind Work Expense (BWE)

Social Security - Above Age 18

Not applicable

 

SSI - Below Age 18

Credit for Student-Earned Income Exclusion (SEIE)

SSI - Above Age 18

Credit for Student-Earned Income Exclusion (SEIE) (up to age 22)

Social Security - Above Age 18

Not applicable

 

SSI - Below Age 18

Credit for Plan for Achieving Self-Support (PASS) (beginning at age 15)

SSI - Above Age 18

Credit for Plan for Achieving Self-Support (PASS)

Social Security - Above Age 18

Not applicable

 

SSI - Below Age 18

Credit for Property Essential to Self Support (PESS)

SSI - Above Age 18

Credit for Property Essential to Self Support (PESS)

Social Security - Above Age 18

Not applicable



Concurrent Exercise
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SSDI/SSI Work Incentives Review Exercise

 

Zoey is a 20 year-old concurrent SSDI beneficiary/SSI recipient who also has both Medicaid and Medicare coverage. She receives childhood disability benefits on her deceased father's work record in the amount of $300 per month and an SSI check of $284. She currently has no other forms of unearned income, is not receiving any in-kind support and maintenance, and is single and lives alone. She has not worked in the past, but recently received her "ticket" from the SSA and considering seeking services from the local employment network.

 

1. Before you offer advice, what are some indicators related to Zoey's potential use of work incentives that you should explore?

 

2. Assuming no potential exists for special work incentives, what would be the immediate effect of part-time employment generating $600 per month on Zoey's cash benefits and medical insurance?

 

3. What would be the effect on her cash benefits and medical insurance if she continues to work at this level of earnings for 13 continuous months?

 

4. What would happen to her cash benefits and medical insurance if Zoey increased her work hours in the 24th month of employment resulting in gross earnings of $900 per month?

 

5. If Zoey quit her job after 40 months of employment what would happen to her benefits?

 

6. What would happen if Zoey had to quit after 50 months of employment?