PROMISE: Lessons learned from six model demonstration projects through the Promoting Readiness of Minors in Supplemental Security Income Project
Section 1: Introduction
Improving educational and employment outcomes for youth with disabilities and reducing long-term Supplemental Security Income (SSI) dependency rank high on the nation’s agenda for federal policymakers. Youth with disabilities receiving SSI face many barriers to making educational progress and gaining early work experiences that promote a successful transition to employment and independence as adults. The severity of their health conditions, family poverty, and confusion about work-related SSI rules and policies create challenges that can limit the opportunities of these youth when transitioning from school to adulthood (Wittenburg & Loprest, 2007).
In January 2019, approximately 1.2 million youth, aged 18 and younger, were SSI recipients, costing in excess of $800 million annually (SSA, 2019).
The number of youth with disabilities who receive SSI payments has been increasing steadily over the past two decades, growing by 55% since December 2000 (SSA, 2014). In January 2019, approximately 1.2 million youth, aged 18 and younger, were SSI recipients, costing in excess of $800 million annually (SSA, 2019). SSI child recipients receive an average monthly payment of $655.49 per month, as reported in December 2018 (SSA, 2019). The number of transition-age youth (ages 16-24) receiving SSI represents approximately 1-2% of the population of all U.S. youth ages. Among special education students, ages 15-18, 21% receive SSI (Honeycutt, Wittenburg, & McLeod, 2014). These trends have given rise to increased concerns among policymakers and professionals regarding future SSI program costs. Equally, if not more important, is the recognition that youth with disabilities should have the opportunity to achieve a meaningful and productive postschool life that includes access to and participation in further education and employment.
The Supplemental Security Income (SSI) Program and Youth
Under the Social Security Administration (SSA) disability eligibility criteria, the SSI program provides cash payments to low-income families that have a child with a severe disability. This means-tested cash payment is often a vital source of income for families of youth under the age of 18. To qualify for SSI, children and their families must meet income, asset, and disability eligibility requirements. To meet the SSI disability eligibility criteria, the youth must have a medically determinable physical or mental impairment that results in marked and severe functional limitations and that can be expected to result in death or that has lasted, or can be expected to last, for a continuous period of not less than 12 months (42 U.S.C. §1382c).
Under the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (P.L. 104-193), when a child reaches age 18 they must have their eligibility for SSI redetermined, using more stringent adult eligibility criteria. Although the eligibility rules, including income limits, for adults are more stringent than those for young people, approximately two-thirds of child SSI recipients continue to receive SSI as adults (SSA, 2019). Among those who exited SSI, significant challenges have also been documented. Hemmeter, Kauff, & Wittenberg (2009), for example, found that those who went off SSI at age 19 were employed, but only a small minority had earnings that were sufficient to replace their child SSI payments. Further, young adults who had exited SSI were more likely to have unmet needs for health care than those who remained on SSI, who have ongoing access to care and health insurance coverage through either Medicaid or non-Medicaid programs (Hemmeter, 2011).
SSA-administered work incentives that can assist SSI youth in achieving employment outcomes are under-utilized because youth and their families are often unaware of or do not understand how to access these incentives and may fear that work will negatively affect their SSI benefits and eligibility.
Federal Policies and Programs Supporting SSI Transition-Age Youth and Families
Several federal laws have been enacted to offer income, health, education, employment, and other types of services and supports for transition-age youth with disabilities. More specifically, these federal laws are intended to help youth become economically self-sufficient as adults and avoid long-term reliance on SSI benefits.
Individuals with Disabilities Education Act (IDEA)
Active youth and parent participation in IEP/transition planning to support post-high-school goals has been advocated for more than three decades. These efforts to strengthen the transition requirements have occurred through periodic reauthorizations of IDEA. The first requirements pertaining to youth and parent participation in IEP/transition planning meetings when transition goals are to be considered were initiated with the 1990 IDEA reauthorization. The 1997 reauthorization of IDEA established age 14 as the minimum age requirement for beginning transition planning, with the intent that transition planning needs to begin early. This was increased to age 16 with the reauthorization of IDEA in 2004. Several states have, however, retained age 14 as the starting age for transition planning. IDEA 2004 requires that transition goals be included in IEPs by the time the student turns 16 (or younger, if determined appropriate by the IEP team or state law) and updated annually thereafter. The IEP must include: (1) appropriate measurable postsecondary goals based upon age-appropriate assessments related to training, education, employment, and, where appropriate, independent living skills; and (2) the transition services (including course of study) needed to assist the youth in reaching these goals. In addition, the public agency (i.e. school) must invite the student with a disability (and parent) to attend the IEP meeting if the purpose of the meeting will be the consideration of postsecondary goals for the student and the transition services needed to assist the student in reaching these goals, as required by IDEA ([34 CFR 300.321(b)] [20 U.S.C. 1414(d)(1)(B)]).
The work incentive targeted specifically to younger SSI recipients is the Student Earned Income Exclusion (SEIE), which allows income to be excluded from benefits calculation if a recipient is a student under age 22.
The law also identifies outside community service agencies (i.e. vocational rehabilitation (VR), service providers, county supports, etc.) as essential participants in the IEP/transition planning process. IDEA 2004 notes that, to the extent appropriate, and with consent of the parents (or child who has reached the age of majority), the public agency (i.e. school) must invite a representative of any participating agency that is likely to be responsible for providing or paying for transition services. Participating agencies may include: vocational rehabilitation (VR); employment and training; postsecondary education programs; local or state health, mental health, or developmental disabilities agencies; SSI benefits counselors; housing; and others relevant to the individual’s needs and preferences. All IEP/transition planning must ensure that the student’s strengths, preferences, and interests are fully considered ([34 CFR 300.43 (a)] [20 U.S.C. 1401(34)]).
Social Security Act Title XVI (SSA)
The SSI program was established in 1972 under Title XVI of the Social Security Act and is administered through the Social Security Administration (SSA). The program provides cash benefits to low income individuals, including youth, who meet financial eligibility requirements and who are blind or have disabilities. SSA’s primary approach for encouraging employment for transition-age youth with disabilities between the ages of 14 and 17 who receive SSI is providing work incentives that allow them to keep at least some of their SSI benefits and Medicaid coverage while they work. The work incentive targeted specifically to younger SSI recipients is the Student Earned Income Exclusion (SEIE), which allows income to be excluded from the benefits calculation if a recipient is a student under age 22.
SSI youth recipients are also eligible for other types of work incentives. The incentives include features to encourage savings (such as the Plan to Achieve Self-Support, or PASS). A specific, and important, support for SSI youth beginning as early as age 14 is Work Incentive Planning and Assistance (WIPA) resources. The goal of WIPA is to serve as a resource to enable SSI youth beneficiaries to receive accurate information and to use that information to make a successful transition to employment. Each WIPA project has Community Work Incentives Coordinators (CWICs) who provide in-depth benefits counseling and conduct outreach to SSI beneficiaries (and their families) who are potentially eligible to participate in federal or state work incentive programs.
Workforce Innovation and Opportunity Act (WIOA)
Passed by Congress in 2014, WIOA is intended to improve the coordination of referrals among the various youth programs; reduce the overlaps in workforce service programs; encourage certain occupational pathways; and shift the emphasis of services from sheltered employment to competitive, integrated employment for youth and adults with disabilities. There are several WIOA provisions that directly affect SSI youth. WIOA requires increased interagency collaboration and integrated service delivery through the development of a combined state plan, which is intended to improve the coordination of education, workforce development, training, and other services at the state and local levels (29 U.S.C. §§ 3112 and 3113).
Title IV of WIOA directly requires vocational rehabilitation agencies to make two major changes (34 CFR § 361.4[a]). First, agencies must provide free employment transition services for eligible high school and postsecondary education students with disabilities and use at a minimum 15% of their federal funding on these services. The required activities of pre-employment transition services (Pre-ETS) include job exploration counseling; work-based learning experiences, which may include in-school, after-school, or community-based opportunities; counseling; opportunities for enrollment in comprehensive transition or postsecondary education programs at institutions of higher education; workplace readiness training to develop social skills and independent living; and instruction in self-advocacy, including peer mentoring. In addition, WIOA allows vocational rehabilitation agencies to work with students who are potentially eligible for services. Previously, agencies could not serve students before they applied and were found eligible for services. However, eligibility for Pre-ETS does not automatically mean services are available and provided. For complete vocational rehabilitation services beyond Pre-ETS, each state’s VR capacity and availability vary.
In addition to these three federal laws, there are several additional federal laws and policies designed to support SSI transition-age youth and families. These include: family income subsidies (Temporary Assistance for Needy Families – TANF); health and mental health services (under either Medicaid or Medicare, determined by eligibility); developmental disabilities service Waivers (Home and Community-Based Services, under Section 1915 of the Social Security Act); housing (HUD Section 8 Housing Choice Voucher Program); and other protections against discrimination in areas of employment, public accommodations, transportation, housing, and other aspects of community living (Americans with Disabilities Act). These federal laws and policies are all part of a complex policy environment that must be navigated to access services, as appropriate and needed, to achieve adult life goals and reduce long-term dependency on SSI benefits.
Service components were based on the federal partners’ review of available research, extensive public input, and consultation with subject-matter experts.
PROMISE: Promoting Readiness of Minors in Supplemental Security Income
PROMISE was established in FY 2013 as a joint initiative of the U.S. Department of Education, Social Security Administration, U.S. Department of Health and Human Services, and the U.S. Department of Labor to fund and evaluate programs that promote positive changes for SSI youth, 14-16 years of age, and their families. This federal agency partnership was established based on the premise that effective partnerships among state and local agencies responsible for programs that provide key services to youth SSI recipients and their families would increase the likelihood that these youth would achieve the long-term goal of independence and economic self-sufficiency in adulthood. For example, the Rehabilitation Act and its implementing regulations require state VR agencies to enter into formal interagency agreements with State educational agencies (SEAs) describing how they will collaboratively plan and coordinate transition services, including Pre-ETS for students with disabilities needing those services (Section 101(a)(11)(D) of the Rehabilitation Act and 34 CFR §361.22(b)). The IDEA also requires SEAs and VR agencies to plan and coordinate transition services for students who receive special education services (Section 612(a)(12) of the IDEA and 34 CFR §300.154). These plans and interagency agreements are essential to ensure that students with disabilities experience a smooth transition from school to post-school activities. It should be noted that the requirements for a formal interagency agreement regarding Pre-ETS and transition services under the Rehabilitation Act apply to a broader population of students with disabilities than only those students receiving services under IDEA.
The Notice of Inviting Applications for the PROMISE initiative included three core aims: (1) establish strong and effective partnerships with agencies responsible for programs that play a key role in providing services to youth SSI recipients and their families; (2) create a plan to develop a set of coordinated services and supports and implement effective practices targeted to needs of youth SSI recipients and their families; and (3) increase the capacity of each PROMISE project to achieve and sustain results based on the best available research evidence on effective interventions and to engage in the testing and rigorous evaluation of the project (U.S. Department of Education, 2013). The federal PROMISE partners intended to use the findings and results of these projects to inform public policy and to build an evidence base for improving postsecondary education and employment outcomes for youth SSI recipients and their families.
In FY 2013, six Model Demonstration Projects (MDPs) across 11 states received five-year funding awards to carry out their proposed activities. The U.S. Department of Education’s Office of Special Education Programs (OSEP) was the federal agency responsible for the administration of the PROMISE MDPs. Under cooperative agreements with the U.S. Department of Education, the six PROMISE MDPs were implemented in Arkansas, California, Maryland, New York, Wisconsin, and a consortium of six western states (Arizona, Utah, Colorado, Montana, North Dakota, & South Dakota), known collectively as Achieving Success by Promoting Readiness for Education and Employment (ASPIRE).
Core Service Components of the PROMISE Initiative
Each PROMISE MDP was required to plan, implement, and evaluate a common set of core service components (U.S. Department of Education, 2013). These service components were based on the federal partners’ review of available research, extensive public input, and consultation with subject-matter experts.
Formal Agency-Level Partnerships
Partnerships served as the foundation on which the PROMISE initiative was established and remain central to each MDP’s implementation. The assertion was that effective partnerships among agencies at the state and local level responsible for programs that provide key services to SSI youth recipients and their families will increase the likelihood of the success of the PROMISE MDPs. The core agencies for these collaborations included —
- State vocational rehabilitation services under Title I of the Rehabilitation Act.
- Special education related services under Part B of IDEA.
- Workforce development services under Title I of the Workforce Innovation Opportunity Act, including youth services.
- Medicaid services under Title XIX of the Social Security Act.
- Temporary Assistance for Needy Families (TANF) under the Personal Responsibility and Work Opportunity Reconciliation Act.
- Developmental/intellectual disabilities services.
- Mental health services.
MDPs were also encouraged to propose other partners they believed would facilitate the success of the project, such as employment networks under the Ticket to Work Program, employers or employer organizations, community colleges, institutions of higher education, independent living centers, agencies that administer or carry out adult education, career and technical education, and maternal and child welfare programs.
The MDPs provided case management services to ensure that services for participating youth and their families are appropriately planned and coordinated and to assist project participants in navigating through the services, supports, and benefits available from the broader service delivery system. Service coordination included transition planning to assist the participating youth in setting individualized post-school goals and to facilitating their transition to an appropriate post-school setting, including postsecondary education, training, and/or competitive, integrated employment (CIE). Transition planning was conducted in coordination with the local educational agency (LEA) and, as appropriate, with the consent of parents or youth who have reached the age of majority under state law. In an effort to support these post-school transition plans, other agency partners, such as the vocational rehabilitation agency, postsecondary education programs, independent living entities, the state Medicaid agency, and workforce investment agencies, were invited to the meetings.
[Work incentives] training was viewed as critical in helping the SSI recipient youth and families understand the impact of employment wages on SSI benefits and how work incentives can be accessed to support employment goals.
Benefits Counseling and Financial Literacy Training
Each MDP included ongoing access to information and resources for youth participants and their families on SSA work incentives. This information and resource connections were viewed as critical in helping the SSI recipient youth and families understand the impact of employment wages on SSI benefits and how work incentives can be accessed to support employment goals. In addition, the MDPs included training on the eligibility requirements of various programs, rules governing earnings and assets, and financial literacy.
Career and Work-Based Learning Experiences
The MDPs provided at least one paid work experience in an integrated setting for youth participating in the project before leaving high school. In addition, other skills development opportunities were provided in an integrated setting, such as volunteering, participating in internships, community services, and on-the-job training experiences, including experiences designed to improve workplace skills (sometimes called “soft skills”).
Parent Training and Information
At a minimum, the MDPs provided information and training to the families of participating youth with respect to: (1) the parents’ or guardians’ role in supporting and advocating for their children’s education and employment goals, including the importance of high expectations for their children’s participation in education and integrated, competitive employment; and (2) resources for improving the education and employment outcomes and the economic self-sufficiency of the families, such as job training and employment services.
Evaluation and Project Assessment Activities
Each MDP was charged with collecting formative evaluation data throughout the course of the intervention delivery, including data related to the fidelity of implementation. This formative evaluation of the project’s activities and model was meant to assess the progress toward achieving project goals and to inform decision-making. Concomitant with this formative evaluation, MDPs were tasked with developing a data collection plan that both informed formative evaluation and allowed for cooperation between MDP data collection systems and Mathematica Policy Research (MPR, PROMISE’s national evaluator). The collection of data and its maintenance also included coordination of state administrative data (including data from education agencies, VR, the State Unemployment Insurance system, and Medicaid), held within each MDP’s Management Information Systems (MIS).
PROMISE Technical Assistance (TA) Center
In FY 2014, the U.S. Department of Education’s Office of Special Education Programs funded a four-year PROMISE Technical Assistance (TA) Center at the Association of University Centers on Disabilities, in partnership with the Institute on Community Integration at the University of Minnesota (see http://promisetacenter.org/). The purpose of the TA Center was to provide technical assistance to the MDPs to support the implementation of these projects and increase their capacity to improve services and supports to youth SSI recipients and their families. More specifically, the PROMISE TA Center —
Assisted MDPs in forming effective partnerships across multiple stakeholders, coordinating and managing systems across agencies, and supporting a shared leadership approach with interactions coalescing around issues, relevant participation, and collaboration.
Supported the MDPs in the coordination of transition support services provided by federal, state, and local governments, as well as supporting the MDPs in overcoming limitations of the current structure of services to help youth SSI recipients transition from high school to postsecondary education and competitive, integrated employment.
Supported the MDPs in increasing their capacity to reach and provide services to families of participating youth, including typically underserved families, such as families with limited English proficiency or of Native American descent.
Provided technical assistance to MDPs on methods and procedures for conducting formative evaluations of their activities to assess their progress, inform their decision-making, and ensure they are implementing their core service components with fidelity.
The information presented in this section of the report described the context within which the U.S. Department of Education’s Office of Special Education Programs established the PROMISE MDPs. The many challenges identified and the requirements placed upon the MDPs represent an important call to action to improve the capacity of state and local agencies to support youth and their families in achieving meaningful postsecondary education and employment outcomes and reducing their dependency on SSI benefits. The next section of the report describes the six MDPs funded over the period 2013-2018 and two no-cost extension periods to establish comprehensive partnerships and implement the multiple service components with the intent of creating long-term, sustainable change that positively impacts SSI youth and their families.