DI 60075: Promoting Opportunity Demonstration (POD)
A. Background on the POD
The Social Security Administration (SSA) is conducting the Promoting Opportunity Demonstration (POD) as required by section 823 of the Bipartisan Budget Act of 2015. SSA is conducting the POD to see if modifying certain rules might help beneficiaries in their efforts to return to work.
The POD tests modifications to certain current program rules applicable to beneficiaries who work and are entitled to Title II disability benefits only or to both Title II and Title XVI benefits based on disability or blindness.
1. Current rules relating to work and benefits
Under current Title II program rules, disability beneficiaries who complete a trial work period (TWP) and subsequently engage in substantial gainful activity (SGA) go into suspense after a 3-month grace period.
2. POD rules
POD participants’ will have their benefits reduced by $1 for every $2 of earnings that are above the POD monthly threshold. The POD monthly threshold is the greater of either: (1) the current year TWP level; or (2) the total amount of a beneficiary’s itemized and approved monthly impairment related work expenses (IRWE). In 2017, the TWP level is $840. The TWP level may increase in subsequent years. If approved IRWE are used as the POD monthly threshold, the IRWE amount may not exceed the SGA amount. In 2017, the SGA amount is $1170 (non-blind) and $1950 (blind). Auxiliaries receiving benefits on a POD beneficiary’s record continue to receive full benefits until the POD beneficiary goes into full offset. See DI 60075.040G.
NOTE: The TWP and the extended period of eligibility (EPE) do not apply to participants during the POD participation period.
B. Purpose of the POD
The purpose of the POD is to test whether gradually reducing benefits and offering benefits counseling will lead to increased earnings and employment for Social Security Disability Insurance (SSDI) beneficiaries.
C. Eligibility for the POD
Based on the requirements outlined in DI 60075.010, the Office of Research, Demonstration, and Employment Support (ORDES) provided a list of 300,000 SSDI-only and concurrent beneficiaries to Mathematica Policy Research (MPR), the contractor tasked with recruitment for and evaluation of the POD. MPR will use this list to contact beneficiaries about volunteering for the POD.
D. Initial field office, processing centers and national 800 number network POD responsibilities
Field Office (FO), Processing Center (PC), and National 800 Number Network (N8NN) sites do not have any role in selecting project participants or in implementing the POD. MPR recruits and enrolls participants on a voluntary basis during the enrollment period from December 2017 through December 2018. If a caller contacts SSA with questions about the legitimacy of the POD, follow the instructions in DI 60075.030A.
E. Implementation responsibilities
1. Abt Associates (Abt)
In order to minimize the impact the POD has on agency resources, SSA contracted with Abt to implement the POD. Abt designed the Information Data System (IDS) that sends data to SSA via the POD Automated System (PAS). As the implementation contractor, Abt’s staff is responsible for:
assisting POD participants with collecting proof of income and IRWE and transmitting it to SSA;
issuing receipts to POD participants for each work report received;
assisting with notice explanation; and
assisting with waiver, reconsideration, and hearing requests for POD overpayments.
2. POD work continuing disability reviews (CDRs)
A POD participant is exempt from work CDRs while participating in the demonstration. Instead, the POD evaluates earnings outside of eWork under the $1 for $2 offset rules.
NOTE: We do not evaluate a POD participant’s earnings for SGA for the period from their last recorded work review decision to the start of their POD participation.
3. POD automated system (PAS)
The PAS maintains a record of the names and SSNs of POD participants randomly assigned to a treatment group. Treatment group participants are eligible to receive the $1 for $2 offset, whereas control group members are not. (For more information on POD groups, see DI 60075.010A). In addition, the PAS accepts a nightly file from Abt’s processing system, IDS, containing earnings and IRWE reports for the beneficiaries who are eligible for the $1 for $2 offset. The PAS processes the earnings and IRWE reports and automatically creates a Manual Adjustment Credit and Award Data Entry (MACADE) action to adjust the monthly benefit. It also generates a notice to the beneficiary explaining the offset benefit. If the PAS cannot generate the MACADE action, it creates an Action Control Record (ACR) in Paperless. The ACR will include the PAS edit code with the processing limitation. The Program Integrity and Targeted Assistance Group (PITAG) or Inquiries & Expedited unit (I&E) in the processing center (PC) of jurisdiction receives and develops the ACR to completion. If a Manual Adjustment, Credit and Award (MADCAP) exception results from the MACADE action, the PITAG or I&E unit in the PC of jurisdiction resolves the exception. Each PC has a centralized group to work the processing limitations generated when PAS cannot automate the MACADE action, as well as to work MADCAP exceptions. If FOs encounter an unworked case, they should send an email to the POD specific email account for the PC of jurisdiction determined by the Program Service Center Office Code (PCOC) on the ACCOUNT line of the Master Beneficiary Record (MBR).
NOTE: For POD Processing Center central email account information, see DI 60075.050A.
F. POD notices
1. Mathematica Policy Research (MPR) letters and surveys
Beginning January 2018, MPR will send recruitment packets soliciting potential POD participants using SSA’s list of SSDI-only and concurrent beneficiaries residing in the demonstration catchment area (See DI 60075.010). If a recipient of the recruitment package agrees to participate in the POD, MPR will randomly assign the beneficiary to one of three groups; Treatment Group 1, Treatment Group 2, or Control Group. (For more information about treatment groups, see DI 60075.010A.) The solicitation process ends in December 2018, or whenever MPR obtains 15,000 volunteers. If an enrollee’s assignment is to the Control Group, MPR will send the beneficiary a notice informing the beneficiary of the assignment. MPR will not send notices to Treatment Group members after random assignment; Abt Associates does this.
After enrollment, MPR will administer a baseline survey, and will send a $25 check to participants that complete the survey. MPR will also send reminders to participants who opt in, reminding them of upcoming surveys they can take. Surveys are sent to members of both treatment groups and the control group.
NOTE: The recruitment packet and notices from MPR are not stored in the Online Retrieval System (ORS).
2. Abt notices
If a participant is randomly assigned to a treatment group, Abt will send a welcome notice with the rules for that treatment group and information about the POD Work Incentive Counselor (WIC) assigned to the beneficiary.
In addition to the welcome notice, Abt sends the following:
Earnings Report Packet: Provides three monthly reporting forms;
Earnings Reporting Reminder: Reminds POD participant of reporting requirements;
Other reminders, as appropriate;
Off-boarding letter: Informs participant that their participation in POD will end in June 2021;
POD exit letter – end of the POD: Informs participants that they are no longer in the POD and have returned to current-law SSDI program rules; and
POD exit letter – withdrawal: Informs participants that they are no longer in the POD and have returned to current-law SSDI program rules.
3. SSA notices
SSA sends the following notices to a POD participant:
POD offset notice explaining monthly offset and new monthly benefit amount (MBA);
benefit rate increase (BRI) adjustment notice correcting the BRI calculation for those POD participants receiving reduced payment amounts due to the POD offset, see DI 60075.055;
end of year reconciliation (EOYR) determination notice comparing reported earnings with actual earnings, see DI 60075.060;
appeal notice providing a reconsideration determination for those wanting to appeal the monthly offset or EOYR determination notice;
termination notice for Treatment Group 2 beneficiaries who have been in full offset for 12 consecutive months;
reminder notice to report earnings if a beneficiary has gone three months without reporting earnings;
end date of POD participation notice explaining when POD participation ends; and
auxiliary notice explaining when payments are not payable, or to explain reinstatement of benefits.