Work Incentives Planning and Assistance National Training and Data Center Serving Post BOND Beneficiaries: What CWICs Need to Know

2 Overview of BOND BOND stands for Benefit Offset National Demonstration, a program of the Social Security Administration. BOND is a new approach to the Social Security Disability Insurance (SSDI) program that is being tested in 10 sites, covering roughly 20 percent of the country. Enrollment in BOND occurred from March 2011 – September 2012 Beneficiaries were randomly assigned into three treatment and two control groups Alabama Arizona/Southeast California Colorado/Wyoming DC Metro Greater Detroit Greater Houston Northern New England South Florida Western New York Wisconsin

3 BOND Treatment and Control Groups T1 & T21 – Treatment groups have ~ 84,400 beneficiaries – Eligible for WIC services & BOND offset – WIC services designed to mirror WIPA T22 – Treatment group has ~ 3,100 beneficiaries – Eligible for EWIC services & BOND offset – EWIC services designed to be “enhanced” version of WIPA C1 & C2 – C1 control group includes all eligible beneficiaries in BOND sites not in the other groups – C2 control group has ~ 4,900 beneficiaries – Eligible for WIPA services

4 Overview of BPP & Offset Beneficiaries in the treatment groups are eligible for a 60-month BOND participation period (BPP) and the potential to receive the BOND offset for up to 60 months – Beneficiaries’ 60-month BOND participation period begins the later of: The first month after their Trial Work Period (TWP) was completed; or The month after they were enrolled in BOND – Beneficiaries’ eligibility for the BOND offset begins the later of: The month after they are found to have a Cessation Date and they complete their Grace Period; or The month after they were enrolled in BOND

5 BPP & Offset Example Example: A beneficiary has a TWP end date of April 2008 and a Random Assignment date of April 2011 The beneficiary's 60-month BOND participation period began in May 2011 and ends in April 2016 (60 months) The beneficiary's eligibility for the BOND offset depends on when the beneficiary is found to have a Cessation Date and completes his/her Grace Period – If the beneficiary was ceased and completed his/her Grace Period sometime before Random Assignment, the beneficiary became eligible for the offset in May 2011, the month following Random Assignment. – If the beneficiary was ceased and completed his/her Grace Period in December 2013 (all after Random Assignment), the beneficiary became eligible for the offset in January 2014, the month following completion of the Grace Period

6 BOND Offset Overview SSA applies the $1 for $2 BOND offset to reduce a beneficiary's SSDI benefit payments for months in BOND participation period when earnings, after allowable deductions, are above the annual BOND threshold amount. – The BOND threshold amount is $13,560 for a non-blind individual and $21,840 for a blind individual in BOND beneficiaries provide an Annual Earnings Estimate (AEE). SSA subtracts any estimates of work incentive deductions and other allowable deductions (i.e., bonuses, vacation pay, disability or sick pay, etc.) from the AEE to determine the beneficiary's BOND countable estimate. Using the BOND countable estimate, the BOND threshold amount is subtracted, and the remaining amount is divided by 2 to factor in the $1 for $2 offset. The total is then divided by the number of months in offset for the year to determine the offset monthly benefit amount, or the amount by which monthly benefits are reduced under the offset rules.

7 BOND Offset Example Calculating a full-year BOND offset Step 1Annual Earnings Estimate (estimate provided by beneficiary)$28,000 Step 2Total Non-Countable Income (estimate provided by beneficiary) $1,800 Step 3 Determine annual BOND countable estimate by subtracting the amount determined in step 2 from the amount determined in Step 1. $26,200 Step 4 Determine annual BOND threshold amount (shown is 2016 amount for non-blind individual) $13,560 Step 5 Subtract the amount determined in Step 4 from the amount determined in Step 3. $12,640 Step 6 Divide the amount determined in Step 5 by 2 (to factor the $1 for $2 offset) $6,320 Step 7 Divide the amount determined in step 6 by 12 to determine the monthly offset amount (rounding up to nearest dime). $ When applying the benefit offset, SSA reduces this beneficiary’s monthly benefit amount by $

8 Why are we introducing BOND to you? BOND beneficiaries will start leaving the BOND program beginning April 1, Each month a new cohort will leave BOND. – Former BOND beneficiaries may contact CWICs directly for services, or – The Help Line may refer calls from beneficiaries who are finished with BOND if still working or seeking work. We want to ensure that they receive good information. We want you to know how/where to begin working with this special group of beneficiaries. We do not want the beneficiaries to have to start over and wait for information-gathering, benefits verification, etc.

9 Here are some things Work Incentives Planning and Assistance (WIPA) staff should know and do as they work with these beneficiaries.

10 Unique Issues of Post-BOND Beneficiaries Beneficiaries are accustomed to once yearly income reporting Benefits have possibly been reduced due to SGA- level earnings but often have not been ceased. Therefore, Part B premiums may have never been billed to the beneficiary. Beneficiaries likely will need support right away with work CDR or overpayment issues.

11 CWIC must verify BOND status Verify BOND status with one of the following: – ETO – Beneficiary’s BPP off-boarding letter – BPQY

12 Identifying Prior BOND Participation in ETO The first step to identifying prior BOND participation is exactly the same as what you currently do before adding a new beneficiary or accepting a new referral from the Help Line. Click on the ‘Search for current WIPA and BOND beneficiaries’ link on the I&R Home Page Enter the beneficiary SSN – do NOT include any dashes or spaces; just enter the nine digit number. 12

13 Identifying Prior BOND Participation in ETO If a matching SSN is found, carefully check the ‘site pull down’ column. When the site shows as ‘ZZ – WIPA BOND’, check the ‘end date’ column. An end date indicates a former BOND participant.

14 Adding a Prior BOND Participant in ETO Once you have determined that a prior BOND participant has an end date, you can move forward to add them in your ETO site. From the I&R Home Page, select ‘Add a Beneficiary’ and complete the demographic information as usual. When you hit ‘Save’, you will see a potential match screen. Click the button ‘Add as New’. Do NOT select the matching record that shows as a possible match.

15 Potential Match Screen

16 Establish what counseling has occurred -Ask if the beneficiary worked with a WIC or EWIC -Ask if the beneficiary has a packet of information to send you

17 Benefits Information Packet As BOND participation terminates, the beneficiary may receive a copy of their benefits analysis and other documents and an envelope addressed to the WIPA servicing the BOND participant’s area of residence. If the beneficiary wishes to have WIPA services, he or she can share this information easily with the WIPA project serving the beneficiary

18 Establish What Has Occurred and What Needs to Happen Investigate current employment status – Is beneficiary working or not, above SGA or not? Investigate current benefits status – Has beneficiary made contact with local field office? – Has post BOND work CDR been initiated or completed?

19 Information about Beneficiary’s Benefit Status In all cases, Social Security will either continue or will begin benefits at the full amount again at the point the beneficiary leaves BOND. In many situations, beneficiaries will have used the Trial Work Period, Cessation, and the Extended Period of Eligibility. Therefore, the first month of post-BOND SGA will terminate benefits.

20 Information about Post-BOND work CDR Local Social Security offices will have responsibility for conducting work CDRs. It is critical that working beneficiaries leaving BOND report their work as soon as possible, and that the report include all current subsidy and Impairment Related Work Expenses applicable to their post-BOND work.

21 More Work CDR Information Post-BOND CDRs exclude the period of BOND participation when making determinations about current work activity. The Social Security field office will look at the person’s earnings the month after their BOND participation ends. At that point, if the person is performing SGA, the benefits terminate. If the person is not performing SGA, benefits are due until the first month the beneficiary again performs SGA. In many cases, the beneficiary will not have had a cessation decision previously. The field office will follow the same process to determine SGA as for any other beneficiary who has never had cessation or used the grace period.

22 Information about Medicare Medicare continuation will depend on the same factors for former BOND participants as with other beneficiaries. When benefits ceased, when the TWP ended, and if the person performed SGA after the 15 th month of the EPE. It is more likely that the EPMC is nearly finished when termination occurs with post-BOND beneficiaries than others.

23 Anticipated Supports Needed BS&A or review of the one beneficiary received Detailed explanation of - work CDR and details of submitting IRWE or Subsidy information - EXR - Medicare/Medicaid - Process for appealing termination - Process for requesting waiver of overpayment

24 Summary When you receive your first request for WIPA services from someone you suspect is a post-BOND beneficiary, review these materials and contact your VCU TA Liaison if you have any questions. Questions today?