WIPA RFA -FINAL-1-29-15.pdf

REQUEST FOR APPLICATIONS

OVERVIEW

Federal Agency:

Social Security Administration (SSA), Office of Research, Demonstration, and Employment

Support

Title:

Work Incentives Planning and Assistance Program (WIPA)

Announcement Type:

New Announcement

Funding Opportunity Number: WIPA-WIP-15-001

Catalog of Federal Domestic Assistance (CFDA) Number:

CFDA 96.008, SSA Work Incentives Planning and Assistance Program

We intend this Funding Opportunity to reflect the following goals outlined in the 2014-2018

Strategic Plan:

• Strategic goal: Deliver innovative, quality services

• Strategic goal: Strengthen the integrity of our programs

• Strategic goal: Serve the public through a stronger, more responsive disability program

• Strategic goal: Build a model workforce to deliver quality service

• Strategic goal: Ensure reliable, secure, and efficient Information Technology services

Source: United States, Social Security Administration, Agency Strategic Plan 2014-2018.

http://www.socialsecurity.gov/agency/asp/

Background:

Congress intended WIPA services to offer community-based support to beneficiaries to begin, maintain, or increase work activity. As funding has remained static, we have altered the service model to focus on in-depth services to beneficiaries who are working or about to work. We have increased Information and Referral (I&R) services via a national call center. This permits WIPA projects to focus intensive services on beneficiaries requiring expertise that WIPA organizations http://www.socialsecurity.gov/agency/asp/ can provide. We are using innovative technology to serve large geographic territories via distance-services. We strengthen the integrity of our programs by assisting beneficiaries to make accurate and timely wage reports. These reports reduce the likelihood and amounts of overpayments. We provide expert technical support and active monitoring to ensure quality services, and we provide secure access to our data system to ensure beneficiary privacy and to improve future iterations of the program.

Dates:

The opening date of this announcement is the date of publication. The closing date for receipt of award applications under this announcement is 5:00PM Eastern Standard Time on March 30, 2015.

Letter of Intent:

We ask prospective applicants to submit on or before February 9, 2015, a letter of intent that includes:

1. This program announcement title, and Funding Opportunity number;

2. A brief description of the intent to apply for a WIPA award and the exact name of the organization that will apply;

3. The name, postal and e-mail addresses, and the telephone and fax numbers of the entity’s director; and

4. Names of the key personnel, if known, as well as partner institutions and agencies.

The letter of intent is not required, is not binding, and does not enter into the review process of a subsequent application. The sole purpose of the letter of intent is to allow Social Security staff to estimate the potential review workload and avoid conflicts of interest in the review. Send the email letter of intent to SSA-TA@grantreview.org.

Pre-application Teleconferences, Webinars and Competition Website

As applicants submit questions regarding the application submission process and programmatic content of this Request for Applications (RFA), we will post a list of questions and answers on the Internet at (http://www.ssa.gov/oag/grants/ssagrant_current.htm#sb=1). Submit questions to

SSA-TA@grantreview.org no later than March 23, 2015. Potential applicants should monitor the website frequently to ensure that they have the latest information, updates and answers.

Additionally, we will post, on the same website, announcements regarding two webinars or teleconferences we will host regarding this opportunity. If you plan to apply, you will need to register for one of these two events. Periodically, we may post important materials to the same website.

mailto:SSA-TA@grantreview.org http://www.ssa.gov/oag/grants/ssagrant_current.htm#sb=1

Full Text Announcement

I. Funding Opportunity Description

Introduction:

Work Incentive Planning and Assistance (WIPA) projects are community-based organizations that provide counseling and support to disabled beneficiaries of the Social Security and

Supplemental Security Income (SSI) programs. On or before August 1, 2015, we will award cooperative agreements for a network of WIPA projects as authorized under Section 1149 of the

Social Security Act. This Funding Opportunity represents the first re-compete of the WIPA program since 2006. With this Funding Opportunity, we seek WIPA cooperative agreement awardees that will provide services across the country through July 31, 2020, pending availability of funds over a five-year period of performance.

The purpose of the program is to support beneficiaries who want to return to work to make a successful and profitable transition to the workforce. Beneficiaries that continue to work improve their economic independence and financial security. WIPA projects help beneficiaries take advantage of our work incentives programs, which may delay or reduce the effect of work on monetary benefits and health insurance. Additionally, WIPA projects act as repositories for information about other work incentives, benefits counseling services, and other resources that may help beneficiaries succeed in their work attempts, or may assist beneficiaries to improve financial stability as they return to work.

WIPA projects serve beneficiaries who are age 14 and older, and receive any of the following benefits based on their own disabilities:

Social Security Disability Insurance Benefits;

Childhood Disability Benefits;

Disabled Widow(er)s Benefits;

SSI based on blindness or disability;

Medicare under the Extended Period of Medicare Coverage (for former disability beneficiaries performing substantial work);

Medicaid under Section 1619(b) of the Social Security Act (for SSI beneficiaries ineligible for payment due to work income);

A State supplementary SSI payment (even if the beneficiary is not due a Federal SSI payment); or

Medicare coverage based on disability and Medicare qualified government employment.

WIPAs provide long term planning for transition-aged youth and may begin providing services to beneficiaries as young as 14. Often, younger individuals with disabilities are not encouraged by school or family supports to consider summer and part-time jobs, build employment resumes, plan for an economically secure future or develop self-concepts as employable individuals.

WIPAs provide support earlier to educate and encourage a smoother transition from the protected school environment to the adult service system, and to a more successful working future.

WIPA projects employ Community Work Incentives Coordinators (CWICs). CWICs counsel beneficiaries about work incentives and the effect of work on other Federal, State, and local benefit programs and employment supports. CWICs are charged with providing beneficiaries with accurate, timely, and understandable information. This includes helping beneficiaries to understand and use programs that support entry into the workforce, such as the Social Security

Ticket to Work program and the Plan to Achieve Self-Support (PASS). CWICs also assist beneficiaries to identify and connect with vocational services and supports, as well as other services, such as Protection and Advocacy for Beneficiaries of Social Security (PABSS), an award program also funded by our agency to assist beneficiaries to remove barriers they may experience that preclude, delay, or deter work goals.

CWICs not only provide guidance to beneficiaries about available work incentives, but also facilitate their use. For example, a CWIC may assist a beneficiary to develop a PASS or may provide guidance to beneficiaries on saving documentation and when and how to submit wage reports to Social Security and other benefit providers.

Because of the complexity of work incentives, disability support, and poverty reduction programs, we require WIPA staff to participate in an intensive training and pass a rigorous certification process prior to working with beneficiaries. We provide extensive technical support via a Social Security contractor, to ensure the technical information disseminated by CWICs is correct and applicable to each participating beneficiary’s situation.

During the training and certification process, prospective CWICs will learn about all of the following topics:

1. Work incentives applicable under Titles II, XVI, XVIII, and XIX of the Social Security

Act, including extended Medicare and continued Medicaid for working individuals;

2. Benefits and work incentives offered under other Federal benefit programs, including, but not limited to, subsidies under Housing and Urban Development (HUD), HUD’s Family

Self Sufficiency program, Supplemental Nutrition Assistance Program, Temporary Aid to

Needy Families, Medicaid programs, including Medicaid waiver services and Medicaid buy-in programs, Veteran’s benefits, and other Federal benefits;

3. Work incentive programs of particular interest to transition-aged youth between the ages of 14 and 25;

4. Poverty reduction programs, including Individual Development Accounts, the Earned

Income Tax Credit, and similar programs;

5. Rehabilitation programs such as those provided by State Vocational Rehabilitation (VR) agencies, Employment Networks (EN), and the Veteran’s Administration;

6. Section 503 of the Rehabilitation Act, as amended;

7. Best practices for marketing to State VR agencies to provide services under the

Workforce Innovation and Opportunities Act (WIOA);

8. Counseling beneficiaries regarding the health insurance programs, regulations, and protections available throughout the United States or territories such as those authorized under the Health Care Portability and Accountability Act (HIPAA), the Consolidated

Omnibus Budget Reconciliation Act (COBRA), Federally mandated Medicaid coverage, Medicare coverage as it relates to disability benefits, and the Affordable Care Act;

9. Conducting outreach with beneficiaries and community partners, including working with the Program Manager for Recruitment and Outreach authorized under Section 1148 of the

Social Security Act;

10. Prioritizing workloads;

11. Conducting effective benefits counseling and analyses for diverse populations and for differing levels of understanding;

12. Methods and procedures for verification of benefits, developing past work, conducting research on benefits using the Social Security Program Operations Manual Systems, and other resources;

13. Preparing written Benefits Summary and Analyses (BS&A) to document the counseling process;

14. Maintaining and protecting beneficiary records;

15. Conducting long-term, intensive beneficiary follow-up to support successful job acquisition and retention;

16. Best practices for providing WIPA services, including outreach to diverse and underserved populations; and

17. Methods of data collection, performance measurement, quality assurance, and best practices for WIPA management, staffing, and supervision.

We expect CWICs to understand how benefits, services, and work incentives interact with the lives and expectations of disability beneficiaries attempting to work. To do this, CWICs must be willing and able to research programs and policies affecting the beneficiaries with whom they work. CWICs verify and analyze benefits, synthesize this information in the context of the person’s work goals, and ensure the services beneficiaries receive are accurate, timely, and useful.

Program History:

Section 1149 of the Social Security Act, which was added by section 121 of Public Law (P.L.)

106-170, the Ticket to Work and Work Incentives Improvement Act, requires that the

Commissioner of Social Security establish a community-based work incentives counseling program. WIPA is the current implementation of this requirement.

We entitled an earlier iteration of these services under the Benefits Planning, Assistance and

Outreach (BPAO) program. BPAO started in 2000 and provided information, referral, benefits counseling, and short-term support to beneficiaries working or thinking about work. The program expired at the end of September 2006.

On October 1, 2006, we awarded cooperative agreements for a WIPA program. Although WIPA served a similar function to BPAO, WIPA services were more intensive, longer-term, and had an enhanced focus on beneficiaries who were working or actively seeking employment. Social

Security issued 106 cooperative agreements at the beginning of the WIPA program. Four WIPA projects closed during subsequent years. On June 30, 2012, Social Security terminated the remaining 102 WIPA projects due to the absence of Congressional appropriation for the program that year.

Congress authorized Social Security to resume WIPA funding with the March 26, 2013

Continuing Resolution (P.L. 113-6). Social Security reopened the WIPA program on August 1, 2013. Not all of the prior awardee organizations were available to provide services. Social

Security negotiated with prior WIPA awardees to provide full coverage of the country. Ninety-five WIPAs currently receive funding that will expire July 31, 2015.

Since the inception of benefits planning under P.L. 106-170, services have become more intensive and targeted to beneficiaries who are serious about working. Current WIPA cooperative agreements provide intensive, long-term support to beneficiaries to assist them not only to begin to work, but to navigate the complex and potentially frightening changes that occur as beneficiaries reduce or eliminate dependence on benefit programs. The current cadre of

WIPAs focuses from 25 to 35 percent of its work effort on basic I&R.

Service Model:

This RFA includes a modified service model that differs from past iterations. Congress established the funding levels for these services in 1999, and the available funding remains unchanged. Because of the leveling of available resources, we require organizations under this iteration of the WIPA program to provide more targeted, comprehensive, and intensive services with a large percentage of those services offered to beneficiaries via distance-based delivery.

We will implement a limitation on general I&R to fifteen percent of the overall work effort, and we encourage projects to use the Help Line (described in the next paragraph) as a general contact number for I&R services. Historically, projects have spent a significant portion of their time responding to inquiries characterized as I&R; that is, providing general information about work incentives, answering questions about the impact of work on benefits, and offering referrals to other employment related agencies. The results of such inquiries do not yield measureable employment outcomes.

Instead, the new service model requires WIPAs to prioritize those beneficiaries that are working or on the brink of work for immediate direct services. The results of WIPA intervention with groups of targeted beneficiaries is more likely to result in measureable and positive employment outcomes.

Our Beneficiary Access and Support Services (BASS) contract with Booz Allen Hamilton is currently responsible for the Help Line operations. The BASS contract expires on September 28, 2015, shortly after we announce the new WIPA awards. We anticipate continuing the Help Line under a new contract scheduled to begin on September 29, 2015. Under this iteration of the

WIPA program, WIPAs will direct or “push” beneficiaries that appear to be earlier in the employment decision process to certified Help Line representatives for I&R services, so that

WIPA staff can focus on intensive benefits planning for targeted beneficiaries. Help Line staff receives training and certification similar to the training CWICs receive, though with the emphasis more on determining appropriate referrals.

In order to target the services to the highest priority populations, WIPA services will focus on beneficiaries who are working, including self-employed, about to begin employment or self-employment (job offer pending or business about to start up), or who, based on informed analysis, are very serious about working and ready to work. A recent Social Security evaluation of the WIPA program, completed by Mathematica Policy Research, found that the majority of beneficiaries seeking WIPA services fall into the following categories:

About four in five recent WIPA enrollees (81.9 percent) were actively engaged in finding a job or were already working when they first contacted a WIPA project . . . . About half of those (41.1 percent overall) were looking for a job and 8.7 percent overall had a job offer pending.

Nearly one-third (32.1 percent) of all WIPA enrollees were already working (30.7 percent employed by someone else, 1.4 percent self-employed). The remainder (18.0 percent) were considering work but not actively pursuing employment.*

* Schimmel, Prenovitz, Livermore, Bryce. “Evaluation of the Work Incentives

Planning and Assistance (WIPA) Program in 2011: Beneficiaries Served, Services Provided, and Program Costs—Final Report.” Page 31.

Mathematica Policy Research. April 30, 2013.

The beneficiaries who are working, actively seeking work, or ready to work are most at need of immediate, in-depth analysis of their benefits situations. WIPA services ensure that beneficiaries understand how work affects their benefits and how WIPA intervention may reduce or eliminate the potential for overpayments. WIPA services also support beneficiaries to begin, maintain, or increase work activity and will help beneficiaries understand how to sustain health insurance under Medicaid or Medicare while working.

The Role of WIPA in the Disability Service Community:

Beneficiaries with disabilities often access an intricate system of services that assist them to meet daily financial and physical needs. Beneficiaries may fear losing these supports if they start to work. In addition, confusion engendered by the complexity of these programs may act as a barrier between the beneficiary and self-sufficiency through employment. In addition to providing direct services, WIPA projects also collaborate and coordinate services with the full range of Federal, State, and local programs and benefits that exist in the WIPA projects’ service areas. WIPA programs disseminate information about work and work incentives to beneficiaries and service providers and offer outreach to underserved populations. The service is free, accessible, and confidential. WIPA assists beneficiaries to anticipate changes, to find resources that may help beneficiaries to continue working, to make appropriate reports, and to build financial stability and success in their goals.

Success for beneficiaries does not simply mean getting a job. Many work attempts fail because of benefit or service changes beneficiaries do not anticipate or understand. For example, a beneficiary may stop working when they receive an overpayment letter, unexpectedly lose a housing subsidy, or lose other supports due to increased income. In order to prevent such an occurrence, WIPA projects provide support from the point a beneficiary seriously considers work until the point the beneficiary no longer needs or desires the assistance the WIPA can provide.

WIPA programs not only provide direct counseling about work incentives and benefits, but they serve as a liaison to employment service providers and link beneficiaries to other services. These may include, but are not limited to, services offered by State Vocational Rehabilitation programs, Employment Networks (ENs) (agencies providing rehabilitation services authorized under

Section 1148 of the Ticket to Work and Work Incentives Improvement Act), America’s Job

Center services, and Protection and Advocacy for Beneficiaries of Social Security (PABSS).

WIPA projects connect beneficiaries to Federal, State, and local poverty programs such as

Individual Development Accounts, the Earned Income Tax Credit and HUD Family Self-

Sufficiency Plans. In addition, WIPAs act as a source of information, counseling, and referral for the many protections for people with disabilities under the law. Examples include, but are not limited to, protections under:

HIPAA;

COBRA;

The Americans with Disabilities Act (ADA);

The Work Opportunities and Innovations Act (WOIA);

Medicaid buy-in programs under the Balanced Budget Act of 1997 and P.L. 106-170; and

Other Federal, State, and local programs designed to meet the needs of beneficiaries attempting a successful entry into the workforce.

WIPA projects must engage in outreach. WIPA outreach serves to inform local service providers about WIPA services and Social Security’s efforts to support work activity. We envision WIPA projects as a clearinghouse for accurate, timely, and appropriate information for beneficiaries, for referrals to other resources in the communities they serve, and as an ongoing comprehensive support to beneficiaries and as a way station on the road to employment. WIPA projects also target transition-aged youth ages 14 to 25, and other underserved populations.

Direct beneficiary-centered benefits counseling remains the WIPAs’ primary objective. Seeking employment is difficult for everyone. It is especially difficult for individuals with disabilities that have been successful in applying for benefits and related supports to assist them to live with a disability. Our programs require applicants to assert that work is not possible at a substantial level, and in some situations, they must prove the limitations that their disability presents. This process can take many months or even years. The successful beneficiary may then fear returning to the workforce at any level since obtaining benefits was such a struggle. However, the result of remaining entirely on benefits is often poverty.

The risk of long-term poverty is especially high for transition-aged youth receiving SSI benefits.

Youth can anticipate long-term poverty if they do not receive sufficient support and encouragement to attempt to work and create an independent and economically self-sufficient future. SSI youth may have family members afraid to lose the security and support SSI provides. In addition, SSI youth are sustained and supported throughout their school years, but must advocate for themselves once they reach adulthood, possibly without the skills to do so.

The current SSI benefit level is below poverty level. Due to the SSI Earned Income Exclusion, SSI beneficiaries who work or are self-employed are usually better off financially. Youth on

SSI, however, usually have no work history or experience with which to build secure futures.

WIPAs should focus on this population to bridge the gap between school supports and the transition to adult life.

Once the beneficiary is convinced to consider the advantages and benefits of employment, ongoing WIPA support is critical. First, WIPA staff provides a safe haven to seek resources that the beneficiary may not realize exist. Second, WIPA projects provide accurate, clear, and comprehensive information and support to enable the beneficiary to navigate the complex programs and work incentives that may provide a cushion for the beneficiary as he or she reenters the job market.

WIPA projects assist beneficiaries to understand their earnings, the effect of earnings on benefits, and when, how, and what to report. WIPA services will help working beneficiaries avoid overpayments, incorrect payments, and underpayments. Unexpected changes, like discovering an overpayment, may permanently discourage beneficiaries from work. Even when overpayments or other changes to benefits are unavoidable, WIPA staff can anticipate such disruptions and support beneficiaries to respond to the challenges that arise. We believe that the most vulnerable adult beneficiary, and thus the highest priority for WIPA service, is someone who is working or beginning to work.

Protocol for Prioritizing Services:

WIPA awardees do not have sufficient resources to serve everyone in the service area. We intend WIPA awardees to direct eighty-five percent of their efforts to intensive benefits counseling. In order to do this, projects must adhere to a prioritizing protocol.

Working individuals are most vulnerable to unexpected changes in benefit and service entitlement, and especially to overpayments. Beneficiaries at risk for the loss of essential supports such as health care coverage, attendant care, and safe housing should be served as soon as possible and should be provided intensive services to ensure that beneficiaries have necessary supports in place. Social Security will provide extensive guidance to successful WIPA awardees on prioritizing services and triaging beneficiaries in most need of support. In general, successful

WIPA applicants will serve beneficiaries, regardless of the referral source, according to the following priorities:

1. Beneficiaries who are working, self-employed full-time, or about to go to work full-time;

2. Beneficiaries working or self-employed part-time or about to go to work part-time;

3. Beneficiaries seriously considering employment, as evidenced by a relationship with a

State VR agency, an Employment Network, or other vocational program, or by self-identification and the results of a CWICs queries; and

4. Beneficiaries who are transition-aged youth, Veterans, or members of underserved populations, seeking resources to assist them to obtain training or education with a clear employment goal.

WIPAs may direct approximately fifteen percent of their total efforts to I&R for beneficiaries in the process of considering employment that need additional guidance.

Social Security will provide additional guidance and in-depth training on the service protocol to all successful applicants.

Limitations on Outreach and Contractual Collaborations:

WIPA projects will expend no more than fifteen percent of their total funding or work effort on outreach for the first year of the five-year cooperative agreement award period. In subsequent years, outreach shall be limited to ten percent of the total award. Outreach includes, but is not limited to, describing WIPA services prominently on the organization’s website; engaging in dialogue with community, local, and State service providers to increase WIPA referrals; and meeting with diverse audiences to describe WIPA services. WIPA projects shall target outreach efforts to reach underserved populations such as transition-aged youth, Veterans, Native

Americans, and other racial, ethnic, disability, and socioeconomically disadvantaged or minority populations.

The National WIPA Training and Technical Assistance (NTC) contractor on behalf of the WIPA projects will develop guidance and training that we will provide to the WIPAs on best practices for outreach activities. At the time of this Funding Opportunity the contractor, providing these services is Virginia Commonwealth University (VCU). The VCU contract expires in June of

2015. We will award a new NTC contract no later than June 30, 2015.

Responsibilities, Expectations, and Roles of WIPA Cooperative Agreements:

Adhering to Terms and Conditions of the Award

WIPA staff will adhere to the Terms and Conditions of the cooperative agreement that we will provide as part of the award document. The Terms and Conditions include, but are not limited to, important requirements to protect Personally Identifiable Information (PII), use of the Social

Security approved data collection system, entering data exclusively into the secure Social

Security furnished laptops, and providing in-depth benefits counseling and comprehensive, long-term support services for SSI beneficiaries with disabilities. We highlight below other critical elements of the Terms and Conditions of the award for the applicant’s information. We will attach the Terms and Conditions of the award to all award documents and we will offer detailed guidance on the requirements contained in the

Terms and Conditions to all awardees following award notification.

Distance-based Services within Designated Area

Successful WIPA applicants will provide WIPA services within and across their designated service areas. Unlike earlier programs where we encouraged face-to-face contact with beneficiaries, we strongly encourage each awardee to provide services via distance methods wherever possible. In the face of limited resources, larger service areas, and improved distance technologies, distance and virtual services facilitate immediate beneficiary services, rather than dealing with travel or transportation challenges. We support teleconferencing, videoconferencing, Skype, Face Time, and related technologies to ‘virtually’ meet in secure environments with beneficiaries. Providing primarily distance support may reduce indirect and overhead budgets, transportation costs, and costs for the physical site. However, we fully support in-person meetings when reasonable.

Accessibility Requirements

Each WIPA will ensure physical, transportation, language, and material access to all beneficiaries in their service area. This includes, but is not limited to, the following:

Physical access, such as barrier-free offices and meeting places;

Offices in locations with access to public transportation;

Distance communication methods accessible to individuals requiring adaptive technology;

Creating websites and other electronic information and communication options that comply with Section 508 of the Rehabilitation Act;

Providing materials in alternate media such as Braille, large print, or electronic media;

and

Providing services and publications in alternate languages, including sign language and alternate languages reflecting the demographic distribution of the service area.

WIPA projects must consider these requirements when preparing the budget request for this

Funding Opportunity, and must describe how the WIPA applicant will ensure access to diverse populations.

Accessible Documentation

Any form of documentation provided by the selected centers (e.g., training manuals, user guides, embedded documents, etc.), including any documentation deliverables required in the request for applications, must be provided in a fully accessible format. The documents must be provided in one of the following formats: Text, RTF, Microsoft Word, or HTML format, or properly

“tagged” PDF. Properly tagged PDFs can be verified by using Adobe Acrobat’s Accessibility

Checker. Documentation delivered in a manner that is interactive (e.g., table of contents, index, search, etc.) must be keyboard navigable, move focus to selected items (or have a keyboard alternative), and be comparable in keyboard access to mouse usage. All images (especially screenshots and technical diagrams that are the sole means for conveying instructions) should include alternative text explaining the image so that a person who is blind can understand the screenshot, chart, figure, etc. Documentation must include information on the accessibility features of the product. If keyboard shortcuts are provided to allow access to program functionality, a list of the keyboard shortcuts shall be provided. Documentation that is delivered in a video or multimedia publication must comply with the Section 508 requirements detailed in

36 CFR part 1194.24 and the functional performance criteria detailed in 36 CFR 1194 Subpart C.

In addition, we require conformance to SSA’s Accessibility Requirements for all video and multi-media deliverables. We do not accept text equivalents used to replace speech, and we require captions to be synchronized with speech. See http://www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-section-508-standards for additional information on accessibility and the Section 508 requirements.

Executive Order 13166 directs each agency providing Federal financial assistance to issue guidance to recipients of such assistance on their legal obligations to take reasonable steps to ensure meaningful access for limited English proficient (LEP) persons under the national origin nondiscrimination provisions of Title VI of the Civil Rights Act of 1964, and implementing regulations (see http://www.lep.gov/13166/AG_021711_EO_13166_Memo_to_Agencies_with_Supplement.pdf).

Applicants can refer to the LEP policy guidance for HHS recipients at http://www.gpo.gov/fdsys/pkg/FR-2003-08-08/pdf/03-20179.pdf. While designed to be a flexible and fact-dependent standard, the starting point is an individualized assessment that balances the following four factors: (1) The number or proportion of LEP persons eligible to be served or likely to be encountered by the program or awardee; (2) the frequency with which LEP individuals come in contact with the program; (3) the nature and importance of the program, activity, or service provided to people’s lives; and (4) the resources available to the awardee/recipient and the cost. A recipient may conclude that different language assistance measures are sufficient for the different types of programs or activities in which it engages, or that, in certain circumstances, recipient-provided language services are not necessary.

Applications should include plans for accommodating LEP persons in light of these four factors.

Suitability Requirements

All staff assigned to the WIPA cooperative agreement, whether paid from Social Security funds, in-kind contributions, or under another arrangement, must have a favorable level five (5) suitability determination from our agency. CWIC and other direct-service staff must hold a level five (5) suitability determination prior to working with beneficiaries. All WIPA staff must apply for level five (5) suitability immediately following notification of the award of a cooperative http://www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-section-508-standards http://www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-section-508-standards http://www.lep.gov/13166/AG_021711_EO_13166_Memo_to_Agencies_with_Supplement.pdf http://www.gpo.gov/fdsys/pkg/FR-2003-08-08/pdf/03-20179.pdf agreement, or must successfully transfer level five suitability to the new cooperative agreement from a prior award. We will provide guidance on securing suitability to all awardees.

Firewall requirements

WIPA awardees may have a parent organization serving as or housing an EN under P.L. 106-

170, the Ticket to Work and Work Incentives Improvement Act, but we will not enter into a cooperative agreement with any entity that we determine would have a conflict of interest.

Therefore, in these situations, the applicant must submit with their application:

A description of the separation of all administrative, budgeting, and direct service duties of the WIPA cooperative agreement and the EN contract staff and services, including assurances that the same individuals are not serving as employees of both the WIPA and the EN;

An organizational and workload chart with clear delineation of roles and responsibilities;

A detailed explanation of how the parent organization will resolve issues when a beneficiary or other stakeholder files a conflict of interest complaint against a CWIC or

WIPA;

An assurance in the form of an affirmative statement that the WIPA will provide the beneficiary comparable information on all available public and private service providers, including all ENs, in their community;

An assurance in the form of an affirmative statement that the applicant will not automatically refer or unduly influence beneficiaries to assign their tickets to the awardee’s EN; and

An assurance in the form of an affirmative statement that beneficiaries receiving services from the WIPA will receive advice about all available work incentive programs, even if those programs could have an impact on milestone or outcome payments under the Ticket to Work program for the EN housed within their organization.

Unlike prior iterations of the WIPA program, we will not consider any exceptions to the firewall requirement between a WIPA and an EN. The WIPA must qualify as a stand-alone and autonomous program.

Similarly, we may award WIPA funding to a Protection and Advocacy (P&A) entity that receives a grant under Section 1150 of the Social Security Act. Applications from P&A organizations must include:

A description of the separation of PABSS files and WIPA files; direct service staff assignments; intake procedures; case management procedures; and complaint processes.

Direct service staff includes individuals who have direct contact with beneficiaries, and supervisors with access to case files. Projects may include executive and administrative staff that do not have direct contact with beneficiaries and do not access case files on both the WIPA and PABSS personnel documentation;

If projects wish to use staff with direct service responsibilities or staff with access to beneficiary information on both WIPA and PABSS awards, the project must submit a written request for an exception regarding the separation of direct service personnel. The request should describe why this individual’s service on both awards benefits the programs, and how the P&A organization will ensure that there is no conflict of interest under the WIPA or PABSS programs; and

This statement should include a clear explanation of how the P&A organization will handle complaints about WIPA services from beneficiaries or other organizations. We must give advance approval before staff with dual responsibilities may work on both the

WIPA and PABSS projects.

Availability for Services

Each WIPA awardee must serve beneficiaries at least five business days per week, with the exception of holidays. We permit flexible hours, and prefer that each awardee have some availability in the evenings or on weekends in order to support beneficiaries with nontraditional work schedules.

Project Focus, Benchmarks, and Performance Measures

The majority of WIPA effort must be directed to one-to-one service to beneficiaries who are working or actively seeking employment or self-employment. These are the populations most in need of support to encourage them to gain, retain, or expand work activity.

Each WIPA awardee must agree to meet or exceed the performance Benchmarks that we will provide. We base these Benchmarks on our experience and data collected from earlier WIPA projects, and they are a reasonable representation of WIPA output. The

Benchmark document is attached as Appendix D.

We will provide information, guidance, and training on Benchmarks and on any other topics and subjects requiring such support throughout the life of the award.

We may develop new Benchmarks and related performance measures based on our two-year data analysis. We will provide training, ongoing support, and technical assistance to all projects on any new performance measures we develop during the fall of 2015.

Summary-Writing Software

We will require WIPA projects to use a uniform and customized BS&A preparation software that we will provide. The purpose of this software is to produce accurate, comprehensive, and consistent BS&A reports. The software requires custom programming of the Federal, State, and local programs unique to each WIPA and the associated service areas. We will provide guidance on how this information must be gathered and submitted. Through a contract, the software will be loaded onto the laptops that we provide to all WIPAs.

Through our training and technical assistance contractor, we will provide expert training to all of the WIPA projects to ensure that staffs have a complete understanding of the Federal, State, and local benefits and services available in their service area as well as the use of the Summary software.

This process will save time, increase comprehensiveness of written analyses, and improve consistency across WIPA projects, but it is not a substitute for developing State and local benefit expertise. As stated elsewhere in this document, the CWIC generating the BS&A will have the responsibility to ensure that the analysis is appropriate, accurate, and applicable to each beneficiary’s unique situation.

WIPA Interaction with Social Security and Social Security Supported Programs:

WIPA projects must have staff available to meet with us for site reviews as requested and must respond to our requests for information within established deadlines.

WIPA staff must participate with us in national calls. These calls allow us and our contractors to communicate information to WIPA staff in a uniform and interactive forum and ensure that project staffs are aware of changes to policies and the availability of resources.

As part of the collaboration and coordination requirements for WIPA, project staffs will work to develop collegial and supportive relationships with the local Social Security offices within the

WIPA service area. WIPA project staffs will reach out to Social Security Area Work Incentive

Coordinators (AWIC) and PASS cadre staff to build relationships. Similarly, WIPA staff shall connect with Social Security field office staff within the service area to foster and maintain positive and collaborative communication.

CWICs must become familiar with the EN available within their service area. CWICs refer beneficiaries to appropriate ENs based on the beneficiary’s expressed needs and interests. We require CWICs to work in cooperation with Federal, State, local, and private agencies, and other organizations that serve beneficiaries with disabilities seeking employment. We will make information available regarding the names and locations of ENs.

What Social Security Will Provide to WIPA Awardees

Through the Training and Technical Assistance contractor, we will offer expert technical assistance, in-depth training, certification, and recertification for CWICs and any other

WIPA staff providing information to beneficiaries.

We will provide secure laptop computers and an approved data collection system for

WIPA awardees to use for all beneficiary specific service data. We will provide technical assistance and training in how to use the data collection system, as well as technical Help Desk support for the hardware and software. We retain the right to the laptop computers. The WIPA data system should contain the only repository of electronic information and PII on beneficiaries served by the WIPA.

We will require users to meet suitability and eligibility criteria as well as provide other assurances prior to issuing the laptops we provide. We will provide successful applicants support and guidance on submitting necessary documentation and on working with our suitability team;

We will assign each awardee a Social Security Project Officer. Project Officers have the responsibility to ensure WIPA awardees meet the program objectives, adhere to the

Terms and Conditions of the award, and are in good standing with our agency. WIPA awardees must send all publications and presentations to their Project Officer for technical review and approval in advance of dissemination. We will also assign Grants

Managers to each WIPA. Grants Managers, from the Office of Acquisitions and Grants, provide guidance and support on financial and budget related matters.

Community Work Incentives Coordinator (CWIC) Responsibilities:

Basic Duties

CWICs provide beneficiaries with accurate, understandable information about work incentives and related employment issues and prepare accurate and detailed reports regarding a beneficiary’s status. This includes helping beneficiaries understand and use programs that support entry into the workforce, including the Social Security Ticket to Work and PASS.

CWICs refer beneficiaries to Federal, State, or local work incentives programs or services supporting return-to-work. We encourage CWICs to develop relationships with service providers within the service area in order to inform these providers about WIPA services, and, in return, CWICs should become more knowledgeable about resources available to beneficiaries with disabilities. This will improve the appropriateness and range of referrals CWICs can provide to beneficiaries receiving services. We also encourage CWICs to collaborate with local

Department of Labor (DOL) American Job Centers, as well as with other community partners that provide employment related services to Social Security beneficiaries with disabilities.

Training, Certification, and Continuing Education Requirements

Any WIPA staff providing information, counseling, guidance, and support to Social Security beneficiaries, must complete the CWIC training and certification from our approved Training and Technical Assistance contractor prior to providing assistance to our beneficiaries. We provide this training and certification free of charge however; projects are responsible for all costs for travel and accommodations.

CWICs facilitate the use of all of Social Security’s work incentives, including, but not limited to, the following:

Impairment Related Work Expenses (IRWE);

PASS;

Student Earned Income Exclusion;

Earned Income Exclusion for SSI;

Blind Work Expenses under SSI for statutory blind beneficiaries;

Extended Medicaid for working beneficiaries authorized under Section 1619(b) of the

Act;

Trial Work Period under the Title II program;

Work incentives used in Substantial Gainful Activity determinations; and

Extended Period of Medicare Coverage.

In addition, CWICs must complete training on the other Federal benefit programs and work incentives, as well as the State, local, and private benefit programs and work supports that exist in their service area. WIPA managers must support CWICs by striving to maintain those relationships and connections in the community and State necessary to providing high quality, accurate, and appropriate services. Prior to working with beneficiaries, CWICs must complete a rigorous training and certification process provided by a Social Security contractor, and like all

WIPA staff, receive a favorable level five suitability determination from our agency.

Through a contractor, we offer an intensive initial training using a comprehensive manual.

Following the initial training class, CWIC trainees must pass a provisional certification process prior to working with beneficiaries. CWICs use actual benefits counseling situations to earn full certification and must earn at least eighteen continuing education credits annually following full certification in order to retain their certification and authority to work with beneficiaries. We will make applicable and informative training available to meet this requirement through our training and technical assistance contract. The contractor will also provide a system of accountability so that CWICs may monitor accumulated credits and determine the credit value of each course offered.

In addition to training on Social Security and SSI work incentives, CWICs must become experts in researching and understanding Medicare, Medicaid, other Federal programs, and State and local programs that assist individuals with disabilities or individuals living in poverty. Our contractor provides information about the Federal benefits, but CWICs must take responsibility to learn the applicable State and local programs beneficiaries may access. It is the CWIC’s responsibility to ensure that the information the beneficiary receives during benefits counseling, in the BS&A, and through other communications, is correct and complete.

Benefits Summary and Analysis

One of the most important documents a CWIC will develop is the BS&A. The BS&A provides a written record of what the CWIC explained or will explain to the beneficiary in meetings. The

BS&A is a synopsis of the benefits the consumer receives and an analysis of the interaction of those benefits with each other and with work income, as well as a description of other services and supports that may benefit the individual.

The BS&A is a critical resource for beneficiaries and a protection for the CWIC. Beneficiaries receiving services are often confused about the services and supports they use. The BS&A provides a clear reference to reinforce the counseling the beneficiary receives. It also protects the CWIC by documenting the information the CWIC gave the beneficiary. If, for example, a beneficiary has an overpayment in the future, the BS&A may offer proof that the CWIC provided accurate information, including the requirement to report changes that would affect entitlement.

Another purpose of the BS&A is to outline the goals the beneficiary has and to help them to meet those goals. If the plan requires actions by the beneficiary, the CWIC, or others, the CWIC should develop a Work Incentives Plan (WIP) to spell out the actions and responsibilities. The

WIP reinforces the BS&A, but it also provides an easy “to do” list to use as a reference as the beneficiary progresses towards his or her employment goal.

Minimum Percentage of Direct Services for CWICs

The work CWICs perform is highly technical. It also requires the ability to communicate to a diverse group of beneficiaries and service providers with different levels of understanding.

CWICs must be excellent communicators. They also must become experts in Federal, State, and local programs, not only through training, but also through research, practice, and experience.

CWIC trainees will dedicate extensive time and resources to achieve certification. CWIC expertise is a perishable skillset, and one that is enhanced with practice. We therefore require a minimum level of services from each CWIC in order to maximize the training and skills development, and to maintain competency. In order to provide services under the WIPA cooperative agreement, CWICs must commit at least forty percent of their total work effort to direct services to beneficiaries, whether Social Security or another source funds the services.