By Ethel Zelenske, Co-Chair, Social Security Task Force Consortium for Citizens with Disabilities
The Consortium for Citizens with Disabilities (CCD) is a working coalition of more than 100 national consumer, advocacy, provider and professional organizations, working together with, and on behalf of, the 57 million children and adults with disabilities and their families living in the United States. The CCD Social Security Task Force focuses on disability policy issues in the Title II disability programs and the Title XVI Supplemental Security Income (SSI) program.
Because of the importance of Title II and SSI benefits to people with significant disabilities, the CCD Social Security Task Force has developed a number of recommendations over the years for strengthening the programs to improve the system’s processes and outcomes. We generally support efforts to improve the disability claims process, including the use of technology, so long as the changes do not infringe on claimants’ rights. The Social Security Administration (SSA) has already implemented a number of significant technological improvements that have helped claimants and their representatives and have made the process more efficient for SSA employees.
A specific area of focus is developing proposals to make the disability benefits system easier for beneficiaries to navigate, particularly when attempting work. One recommendation is that SSA develop a better wage reporting and recording system and promptly adjusting benefit payments to reduce overpayments. The delay in processing of earnings reports often has a very detrimental impact on people with disabilities. When beneficiaries faithfully notify SSA of earnings or other changes that may reduce their benefit payment amounts, it may be months or years before SSA sends an overpayment notice to the beneficiary, demanding repayment of sometimes tens of thousands of dollars of accrued overpayments. It is shocking to beneficiaries to receive these notices, when they reasonably assumed that SSA had processed the information they submitted, and it is challenging, if not impossible, for someone subsisting on benefits alone to repay the overpayments. Many individuals with disabilities are wary of attempting a return to work out of fear that this may give rise to an overpayment, resulting in a loss of economic stability and health care coverage upon which they rely.
We also have recommended that an earnings offset be established in the Title II disability program, similar to the one that has existed for more than 25 years in the SSI program. One of the most enduring barriers to work for beneficiaries is the sudden termination of cash benefits when someone crosses the substantial gainful activity (SGA) threshold after the trial work period. This affects both the individual’s benefits as well as those of any dependent(s). We recommend establishing a $1 for $2 earnings offset in SSDI to parallel the provision in the SSI program. An earnings offset would eliminate the “cash cliff” for beneficiaries who are able to work and would help ensure that individuals are financially better off by earning wages than by not earning. This long-overdue proposal is currently being tested. The disability community has been advocating for this change for decades.