Promoting Readiness of Minors in Supplemental Security Income (PROMISE)

Thank you for your interest in the PROMISE program. PROMISE is a joint initiative of the U.S. Department of Education (ED), the U.S. Social Security Administration, the U.S. Department of Health and Human Services, and the U.S. Department of Labor to fund model demonstration projects in States to promote positive short-term and long-term outcomes for children who receive Supplemental Security Income (SSI) and their families.

In order to run a rigorous competition and obligate the funds available for this program to grantees before September 30, 2013, ED will waive rulemaking for this new program, pursuant to its authority in section 437(d)(1) of the General Education Provisions Act. We encourage all interested parties to review the PROMISE Public Input Notice (PIN) and offer your input on key program areas with us. Comments will be accepted until 5:00 PM EDT on March 17, 2013. We will review and consider the public input as we develop the final priority that will be published in a Notice Inviting Applications in the Federal Register later this spring.

All posts will be reviewed before they are posted. We intend to post all responsive submissions on a timely basis. We reserve the right not to post comments that are unrelated to this request, are inconsistent with ED’s Website policies, are advertisements or endorsements, or are otherwise inappropriate. Please do not include links to advertisements or endorsements, as we will delete them before we post your comments. Additionally, to protect your privacy and the privacy of others, please do not include personally identifiable information such as names, Social Security numbers, addresses, phone numbers, or email addresses in the body of your comments. For more information, please be sure to read the “comments policy.”

Please understand that posts must be related to the PROMISE program priority and should be as specific as possible. Each post must be limited to 1,000 words. All opinions, ideas, suggestions, and comments are considered informal input and ED will not respond to any posts. If you include a link to additional information in your post, we urge you to ensure that the linked information is accessible to all individuals, including individuals with disabilities who require accessible formats. We look forward to receiving your ideas and suggestions. However, please be aware that the input you provide in these posts might or might not be reflected in the final notice inviting applications that will be published in the Federal Register.

Again, thank you for your interest in this opportunity to promote positive outcomes for children who receive SSI and their families. We look forward to hearing from you.

Selected Areas for Input

1. Request for specific input on the Overview of Program section:

  • Should an organization other than a State agency be eligible to apply as the lead coordinating entity as long as the leadership of the organization is appointed by (or is under the authority of) the Governor?
  • Would a non-State entity have the ability to effectively bring together the necessary partners and coordinate program activities?
  • Under the draft priority, a child SSI recipient must be between the ages of 14 and 16 at the time their project services are initiated to be eligible to participate in the MDP. This will allow the child and family participants to receive at least two years of project services prior to the child’s age 18 SSI redetermination. Should the priority also allow child SSI recipients who are 17 years of age when services are initiated to participate in the MDP? Or do participants need to receive more than one year of project services prior to the age 18 SSI redetermination in order to achieve the desired outcomes of this program?

2. Request for specific input on the Priority Section:

  • Given the administrative structure in your State and the State programs that must be included in the partnership (see (a)(1) under Project Activities), would the partnership requirements in this notice be a significant barrier to implementing a successful project in your State? If so, what are those barriers?
  • Are there State programs or other entities that should be added or removed from the list of required partners in order to ensure that the project can achieve the goals of the PROMISE program? If so, which ones?
  • What programs and strategies at the State or local level have shown great potential or have been proven to improve educational, employment, or other key outcomes for child SSI recipients and their families?

3. Request for general input on the Participant Outreach and Recruitment section.

4.  Request for general input on the Technical Assistance and Training section.

5. Request for general input on the Evaluation and Project Assessment Activities section.

6. Request for specific input on the Performance Measures section:

  • Do States have an existing management information system or system that could be easily adapted for the purpose of managing the MDP? For example, a State may have a system that has the capacity to track referrals and service participation, including documenting the services and supports received by the child and their family.

7. Request for general input on the Other Project Requirements section.

8. Request for specific input on the Application Requirements section:

  • What waivers should be available to the PROMISE MDPs? Of particular interest are the waiver authorities of programs administered by the U.S. Departments of Education, Labor, and Health and Human Services, and the Social Security Administration.
  • What are the legislative, regulatory, or other barriers that impede a community’s ability to implement the most cost-effective strategies to assist children who receive SSI and their families?

9. Request for specific input on the Awards section:

  • Is it feasible to use the OBP model for this grant? The OBP model is currently being pursued under existing authority by the Departments of Labor and Justice. What are the challenges and benefits?

10. Request for general input on the Definitions section.

11. Request for general input on the Selection Criteria section.

12. Other comments on the PROMISE initiative.

* When providing comment, please include the request for input number from above in which your comment relates.

30 Comments

  1. Section 1 – The US DOE and the State funded Parent Centers should be eligible to apply as the lead agencies for this initiative. These centers most often act as a central hub in the community and have the expertise and committment to do this work effectively and efficiently. As far as the technical assistance and training directive mentioned in section # 4, funded programs should be required to partner with the existing parent centers who currently have training curriculum that is effective and successfully delivered. The federal and state funded parent centers focus on collaboration, bringing networks and agencies together and creating agreement always focused on improving outcomes for persons with differing abilities. The PROMISE program is a proposed collaboration amongst agencies that typically work independently. The models of collaboration created by the parent centers will set the standard for this initiative. To review, it is my recommendaton that the Parent Centers should be eligible to apply for this program as a lead, coordinating agency. If the program is lead by another agency, they should be required to partner with the existing parent centers.

  2. The Co-Chairs of the Consortium for Citizens with Disabilities Social Security Task Force, Education Task Force, and Employment and Training Task Force are pleased to provide comments on the PROMISE Public Input Notice (PIN). Our full comments can be viewed at:

    https://docs.google.com/file/d/0B6jqlLC67q60R185eElmZ1hiSHM/edit?usp=sharing

    Our comments can also be downloaded as a Word document at:

    https://www.dropbox.com/s/ilhroj0qa1nklxe/CCD%20Comments%20on%20PROMISE%20Mar%2017%202013.doc

    Thank you for the opportunity to submit comments.

  3. Item #1: Very few states will be eligible given the sample size restrictions. Those who are eligible are highly-populated and urban-centered. Those areas will not be likely to produce results/models that are replicatable in rural and frontier areas. While consortuiums of rural and frontier areas are a possibility, such projects are often extreemly difficult to lead, and slow to procude meaningful results given the significant variations in the systems that must be involved. Reduction in sample size and/or broadening of the target age range is essential to producing outcomes relevant to all, and can be done with smaller budgets to equal the same national budget. Also, a neutral entity application consideration (i.e. outside of a state agency) will allow all partners in an eligible area to consider the likelihood of increased productivity on the project if business practices relevant to the project can be conducted outside of the often slow and beaurecratic systems required when executing business within state agencies.

  4. 1. A US DOE/OSEP-funded parent center should be eligible to apply as the lead coordinating entity. Parent centers have the knowledge, capacity, experience, expertise and commitment to do this work effectively and efficiently. Parent centers do not have hiring freezes that are impacting many state agencies. Parent centers have the trust of families and already have relationships with the necessary partners and experience coordinating their efforts through other projects.

    2. The partnership requirements should include the State Title V program funded by the US Dept.Health &Human Services Maternal & Child Health Bureau. Title V programs focus on 6 core outcomes for children & youth with special needs including effective transition to adult systems of care. Independent Living Centers should be added. We would also support extending the age of eligibility to age 17.

    3. States should be required to include the full diversity of youth with disabilities in their state including by race, ethnicity, language, SES, geographic location, etc. The needs of youth living with a disability vary greatly across these groups.

    4. Programs should be required to partner meaningfully with US DOE/OSEP-funded parent centers (if the program is not housed at that center) to provide intensive training, TA & support to families of youth in the program about IEP & transition to adult services required by IDEA.
    5. It needs to be clear which services are expected to be provided to the intervention group that are not already required of school districts under the transition related sections of the IDEA. Many of the services you highlight (e.g., case management, benefits counseling, and and work-based learning) are all potential transition services that should be readily available to all students. Having clear information about what is required under IDEA and what additional services would be provided under this initiative will help in delineating responsibilities among partners, in particular VR and State Developmental Disabilities officials. It will also help delineate intervention and control groups.

    6. We agree with Deb’s comment that “With 30% parents not completing high school, can GED for parents be considered as role modeling for their children? Consider TANF reduction as outcome too…FAMILY outcomes are important too. Remember improvements to the FAMILY could improve outcomes for the children.”

    8. To braid an important resource for ensuring student post-secondary success, SSA should consider providing a Ticket to Work waiver allowing students to receive a Ticket as early as age 18. The Ticket to Work Panel made this recommendation several years ago, although SSA never tested the impact of providing this as a potential waiver at the time.

  5. PACER is a nonprofit that is Minnesota based and a national parent center that works to expand opportunities and enhance the quality of life of children and young adults with disabilities and their families in our State and nationwide. Our decades of operation and experience of our staff provide us with the perspective to provide input on this initiative. Thank you for the opportunity to comment.

    It is critical for resources to be focused on improving outcomes for students who receive Supplemental Security Income and their families. Due to the fact that many agencies run programs which are in a position to assist in improving these outcomes, the multi-agency approach to this initiative is much needed. In addition, parent and family engagement, which is recognized as a key component in this initiative, is vital to its success.

    On the questions that the Department is specifically seeking information on, our thoughts are as follows:

    SSI recipients who are 17 receiving a priority for services – We believe that children who are 17 years of age should also receive a priority for services. While at least two years of services is ideal to ensure the necessary impact, children receiving one year of services can also benefit.

    State partnership requirements – We strongly support the existing requirements for multi-agency participation as a part of this initiative. In addition, we believe that this requirement would be further strengthened with the inclusion of a Statewide parent training and information center in each state. Statewide parent centers, like PACER, have the capacity as well as significant experience in working with children with disabilities and their families, including those who receive SSI. Their inclusion as a mandatory partner would ensure that the critical family engagement element of this initiative becomes a reality.

    State and Local Strategies that produce outcomes for SSI recipients and their families – Two particular strategies, in the experience of PACER and other parent centers around the country, that have been particularly effective for children with disabilities and their families are parental/family engagement and work experiences and related activities. Parent engagement, when done with fidelity, can have an enormous impact in helping parents pursue better education, employment and social emotional outcomes for their children. Often families are confused about the impact of employment on health and SSI benefits. Strategies that involve outreach materials, parent training and easily accessible resources such as a national helpline can all be successfully employed in producing better outcomes and respond to parent concerns.
    Additionally, efforts at expanding career awareness, work experiences, and postsecondary education support are critical strategies to drive better outcomes for SSI recipients. As young SSI recipients and those that provide them services plan for their futures, exposure to possible careers, work experiences and support to attend college are essential. These strategies have been utilized in programs in which PACER has participated and produced positive results.

    Waivers of existing statutory requirements – It is certainly possible that some discrete and well-targeted waivers may be necessary for this initiative to produce positive outcomes. However, waivers for certain areas of law, particularly IDEA, should not be considered if they are going to jeopardize existing protections and supports for students with disabilities. IDEA in particular does not provide for any type of waiver authority that would likely be helpful to this initiative and the authority to issue such waivers should not be expanded through these Promise Grants.

    Requirement to form consortia for States with small numbers of SSI recipients – We are concerned that States with less than 2000 SSI recipients would be forced to form consortia with other States in order to participate. We propose that States with less than 2000 SSI recipients be afforded the opportunity to participate without forming consortia with other states and receive an amount that would be proportionate to the amount a State with 2000 recipients would receive.

    Thank you again for the opportunity to comment.
    Paula Goldberg
    Executive Director
    PACER Center
    http://www.pacer.org

  6. America Forward is a non-partisan policy initiative, spearheaded by the national venture philanthropy and social innovation firm New Profit Inc. We foster collaboration between national policy makers and innovators who have created high-impact organizations that get results, to advance a public policy agenda that champions innovative and effective solutions to our country’s most pressing social problems. We advance our efforts through the leadership of the America Forward Coalition, a network of over 50 innovative, impact-oriented organizations, working in more than 900 communities nationwide, dedicated to driving systemic change in workforce development, education, and early childhood. Our Coalition members share a commitment to innovating to achieve better results, using data to track progress and ensure accountability, and leveraging resources across silos and sectors to improve the lives of the people they serve. America Forward organizations are achieving measurable outcomes in communities across the country every day. We believe that innovative policy approaches that foster innovation, reward results, and catalyze cross-sector partnerships can transform these local results into national change and propel all of America forward.

    America Forward is thankful for the opportunity to submit comments on the Promoting Readiness of Minors in Supplemental Security Income (PROMISE) Initiative.

    The Public Input Notice (PIN) requests input on whether an organization other than a State agency should be eligible to apply as the lead coordinating entity, and whether a non-State entity would have the ability to effectively bring together the necessary partners and coordinate program activities (Item 1):

    As currently drafted, the PIN defines eligible applicants as the 50 States and the District of Columbia. America Forward believes that in cases where there is an organization with experience in effectively working with State agencies, it should be considered as an eligible applicant and allowed to apply as a lead coordinating agency. In addition, America Forward believes there are numerous examples of non-State entities that have experience and expertise in coordination, data management, performance management, and partnership activities that could help to coordinate and complement State agency activities under PROMISE.

    The PIN requests input on programs and strategies at the State or local level that have shown great potential or have been proven to improve educational, employment, or other key outcomes for child SSI recipients and their families (Item 2):

    America Forward Coalition member organization profiles include SSI children who are approaching, are at, or have recently passed the SSI transition age. Our organizations have achieved extraordinary success in transitioning low-income youth with multiple barriers through customized education and training, experiential learning, work experience and supportive services to very high levels of success in careers and post-secondary education. We believe our organizations and similar groups could be engaged to focus additionally and specifically on SSI children around the transition age.

    The PIN requests input on whether applicants should be authorized to propose waivers of various requirements under existing programs to help encourage successful implementation of PROMISE projects (Item 8):

    Often times, statutory, regulatory, and/or administrative requirements hamper the ability of grantees to utilize innovative approaches in the development and implementation of federally-supported programs. Accordingly, America Forward believes that PROMISE applicants should be able to propose waivers of various bureaucratic requirements as long as they are held accountable for specific, predetermined outcomes. The appropriate use of waivers can help to provide a more flexible and seamless delivery of PROMISE projects while also ensuring that applicants provide services in a more effective and results-oriented manner.

    The PIN requested input on the feasibility of the invitational priority for applications that propose to incorporate an Outcome-based Payment (OBP) model (including performance-based contracting) that ties payments to providers based on the achievement of outcomes or established milestones (Item 9):

    Historically, the federal government has supported programs regardless of whether the services delivered actually achieved results, as long as providers met federally-prescribed rules that generally focused on inputs. As a result, the federal government has funded programs that haven’t necessarily worked, costing taxpayers and negatively impacting the very individuals that programs were intended to help.

    America Forward believes that OBP models (including Pay for Performance contracting) have the potential to change the status quo and ensure that federal funds are spent in a more effective manner. Under Pay for Performance contracting models, government dollars are paid out when providers achieve intended results for the people they serve. Programs enjoy flexibility from bureaucratic requirements that often accompany the design of federal initiatives and in return, receive federal support based on the extent to which they meet performance measures.

    America Forward supports similar efforts underway at the Department of Labor (including Pay for Success Pilots under the Workforce Innovation Fund) and is encouraged by recent efforts in Congress that would support the development and implementation of Pay for Performance initiatives including S. 3599, the Careers through Responsive, Efficient, and Effective Retraining (CAREER) Act (introduced in the 112th Congress) and H.R. 803, the Supporting Knowledge and Investing in Lifelong Skills (SKILLS) Act.

  7. We appreciate the opportunity to comment on the draft priority for the PROMISE Program.

    The expenses incurred and the income lost when a care taker reduces his or her work hours or leaves a job altogether to care for a family member have significant impact for the entire family and their financial stability. The modest income that SSI provides allows families to support and care for family members with disabilities in their own homes and to meet their needs.

    Overview of the Program:
    Partnerships with key stakeholders will be critical to success. We recommend:
    • Each MDP should involve families and youth with disabilities in providing input about the challenges and needs of youth and incorporate that input into the design and implementation of the projects.
    • Schools and community based organizations that serve youth with disabilities should play a substantial role in the development and implementation of the projects.

    We support the inclusion of older youth and young adults (beyond 14-16 years old) in PROMISE. Expanding the age restriction would allow the projects to look at the impact of interventions beyond the redetermination age and at challenges that may arise shortly after redetermination.

    We also urge that MDPs develop processes to ensure that participants and their families are not negatively affected through participation in the project. For example, if youth and families are able to increase their income and reduce their SSI receipt but struggle to maintain this shortly after the pilot project, continued support to the family or youth should be available.

    Services and Supports:
    We support the requirements for MDPs to provide or arrange for case management, benefits counseling, career and work-based learning experiences and parent training and information. These supports are critical for youth and families and should be culturally and linguistically accessible to limited English speaking families and youth from diverse backgrounds participating in the projects. Supports and services should include resources available in the communities where youth and families live to ensure accessibility and diverse perspectives on disability.

    We also urge that benefits counseling be explicitly included in the parent training and information service component. Some parents may serve as the representative payee for their minor children, and for adult children in their care and should be aware of the benefits available to those they care for.

    In addition, while CLASP’s broader youth work has found that no one program model or intervention can meet the scale of the challenge or diverse needs of young people in distressed communities, commonalities have been documented in practice and in research that result in positive outcomes. These components are essential if a program is to address the range of needs encountered when working with groups with significant barriers to employment:
    • A caring adult advocacy and support system helps youth navigate a complex maze of programs, services and educational options, and it guides them in choosing the set of services that best suits their individual needs. Such a system creates a personal relationship of respect and support between young people and well-trained, caring adult advocates. This relationship should continue until the young person achieves stability in the labor market.
    • Many youth with disabilities may enter the pilots in need of academic remediation. Integrating remediation with occupational instruction reduces the time to credentials compared to the more common approach of requiring students to complete remediation before starting occupational coursework. It accelerates learning by customizing the basic skills and remedial coursework to the student’s occupational objectives and provides for an easier transition to higher-level study or certification. Given the range of education/competency levels of participants, it is critical to design multiple entry points to services.
    • Providing rich work experiences and workplace connections that require exposure to work and to people who work as role models. The array of work-related options should include subsidized employment, work experience, internships, paid or stipend community service, on-the-job training, tryout employment, part- and full-time employment and college work study. These offerings should be arranged along a continuum that enables young people to progress from the most sheltered experiences to unsubsidized private-sector workplaces, depending on their level of work preparedness and comfort.
    • Personal development/leadership and civic responsibility. Preparing youth for success in postsecondary endeavors and for advancement in the workplace requires not only developing their critical academic and occupational skills but also honing their personal, communication, social and life-management skills and should be a key objective of program intervention.

    Participant Outreach and Recruitment:
    We encourage outreach to local organizations serving youth with disabilities and urge targeted outreach to diverse communities.

    Performance Measures:
    Sites should document the characteristics of the participants served, and the extent to which they are, or are not, representative of the full range of SSI youth. To the extent that these pilots are designed to provide information for potential future policy changes, it is important that the results not be biased by the selection of participants who are more likely to succeed than the typical SSI recipient.

    Application Requirements (Waivers):
    Waivers regarding the use of funds are most appropriate when there is clear agreement on the goals of a program, and there is reason to believe that these goals could be achieved more effectively or efficiently through activities other than those that are currently funded. Such waivers require careful data collection on the populations served (or not served), their outcomes, and the full cost of services (including those paid for by other funding streams).

    Data Collection:
    We urge that MDPs collect qualitative data through interviews with youth participants, their families, and community service providers that are providing support to them. Qualitative data is critical to capturing and understanding the experiences of youth and their families and how those experiences contribute to their success.

    It is also critical to collect data regarding the diverse backgrounds of participants such as racial and ethnic data, language preference, family income at the beginning and end of program participation, other community resources and supports and whether they are from rural, urban or suburban communities.

  8. States have been informed through the PROMISE conference calls that SSA may not be providing any identifying information on SSI beneficiaries. Rather, state and local agencies would be required to identify presumed SSI beneficiaries through local outreach efforts and provide personal identifying information to a SSA contractor for beneficiary confirmation. This is especially problematic for those states that are otherwise prohibited from requesting social security numbers for the purposes of enrollment in public schools or the receipt of special education services. It is recommended that SSA provides the states with the identifying information on the targeted SSI student population. This will allow states to conduct a focused recruitment of SSI beneficiaries and eliminate costly and intrusive outreach efforts to families with children with disabilities who may not be receiving SSI benefits.

  9. The PROMISE Program sounds like a wonderful and exciting opportunity to help youth with disabilities live fuller, more productive and more independent lives. The opportunity to work creates endless possibilities and may even help break the cycle of poverty that many individuals with disabilities have become accustomed to. I would like to comment on just a few items that I feel are important considerations which may impact the success of the program:

    1. I understand that certain programs and projects require a control group as a method to determine if the program/project achieves anticipated results; however, I do not understand the benefit of establishing a control group with PROMISE. We all, unfortunately, see where we are at without it already. If we spend the time to truly provide a quality program that is focused on this population of youth and their families, and then focus on the positive impact PROMISE has on those who are involved, wouldn’t it stand to reason that we would be able to determine if anticipated results were reached without a control group?

    2. I also agree with the commentor who stated that PROMISE should include a sampling of urban, suburban and rural areas. Just because these children and families recieve SSI benefits does not mean that their situations are all the same or even similar. My fear is that if states focus on the largest cities, the PROMISE results will not accurately reflect the unique challenges faced by those who live in rural communities – those where a lack of jobs and transportation remain a constant barrier to employment.

    3. I also believe it would be beneficial to mandate that Independent Living Centers be included as part of the PROMISE collaboration since they already provide services and supports to persons with disabilities – all ages and all disabilities.

    Thank you for the opportunity to share my thoughts.

  10. Input Area 1: Overview of Program Section:

    •Leadership criteria:
    A non-state entity could have the expertise and capacity to bring together the necessary partners and coordinate activities, however, they would not have the authority to ensure follow through. A gubernatorial or federal mandate would provide that authority.

    •Age criteria:
    Many students with an IEP are in school until age 21. The age range should be expanded to include children ages 14-18, to allow for older participants to be followed until the end of their school career. Age 18 maximizes the minimum of 3 years of follow along available through the PROMISE initiative. Many individuals/families are fearful of the potential of losing benefits. States thus may have difficulty identifying willing participants. By expanding the age eligibility criteria, a larger pool of viable participants can be anticipated. As an added incentive perhaps a waiver could be provided to defer eligibility redetermination to age 21 for participants in PROMISE. This idea is similar to the deferred redetermination for participants in the Ticket to Work program. In order to validly assess the effectiveness of the program, participants must be followed for at least 2 years.

    Input Area 2: Priority Section:

    •Required partners criteria:
    Centers for Independent Living (CILs) should be included as mandated partners. CILs are the only cross-disability organizations existing nationally that provide a life span of services specifically committed to promoting and sustaining self-sufficiency. Including CILs in the MDPs will ensure that participants have access to a single community-based whole-person resource that will remain available beyond the project period.

    •Programs/strategies showing great potential:
    In states where partnerships exist between key state agencies and the CILs, individuals with disabilities have access to services and supports that were not in place prior to these partnerships. The Promoting Self Advocacy project in NJ is an example of a successful partnership. Since 2003 the NJ Association of CILs in partnership with NJDOE and NJDVRS supported over 25,000 students through the provision of education and training including life skills, independent living skills, and self advocacy, self-determination, and conflict resolution, peer mentoring and post-school supports. Recently, job seeking skills and other employment readiness skills were added to the project to ensure students were well prepared for transition from school to post-secondary education/training or employment.

    Input Area 3: Participant Outreach and Recruitment Section:

    •Participant Outreach:
    The plan for outreach and recruitment must include information to address the common fears among individuals on SSI with regard to rolling off benefits. Without that, states will have difficulty identifying 2,000 willing participants.

    Input Area 9: Awards Section:

    •OBP model feasibility:
    An exclusively OBP model may create obstacles based on the current ways of working for local and state agencies and may serve as a disincentive for participation. A more feasible alternative would be to offer a fixed rate for a minimum outcome with the potential for added financial incentives based on higher levels of milestones and outcomes.

  11. ITEM 1. The age should be expanded from 14 to 16 years of age to 13 to 17 years of age to ensure the necessary pool of applicants is reached.

    ITEM 2. Partners in the justice system who focus specifically on juvenile offenders and child in need of care cases should be listed (e.g. Citizen Review Board and CASA).

  12. Comments related to:

    Item 1: We encourage flexibility for states in designating the lead agency, including the possibility of a private nonprofit organization. States know their situation well and have spent many years building partnerships that will be valuable in implementing this initiative. A nonprofit lead has the potential to act more quickly than a government agency.

    Item 3 To assure uniformity in outreach materials, we urge the federal agencies to require the contractor selected for the research to produce the materials for each state to use in recruiting project participants.

    Item 3 We ask for a reduction in size of treatment and control groups recognizing that 1) smaller states will have difficulty recruiting such a large number and 2) the project complexity will make it difficult enough to accomplish within one state and a real deterrent to multi-state efforts.

  13. I beleive strongly that this program should require a sampling of participants spread accross Urban, Suburban and Rural populations. The needs of persons living with a disability vary accross these regions.

  14. RE: Request for specific input on the Priority Section

    Independent Living Centers (ILC’s) Should be added as a mandated partner. ILC’s provide services to persons of all ages with differing disabilities in order for them to live as independent as possible.

  15. Thank you for the opportunity to comment. Regarding the question under Overview of the Program relating to whether the lead coordinating entity can include an organization other than a state agency, there are three circumstances to consider. One, there may be considerable benefit from having a neutral entity coordinate the project activity among various state agencies whose involvement is essential but who whose cooperation may be difficult to secure when each operates under disparate regulations, mandates, and outcome measurements. Second, state agencies are often subject to hiring and procurement processes that are likely to delay implementation of the project for several months. And third, when a consortium of states might join together to achieve the numbers for random assignment there will be questions of which state takes the lead and which state entity within that state oversees the project. Further, individual state members of a consortia will have different processes for accepting and distributing funds which could make project start-up and implementation additionally complicated. And finally under the third scenario, insuring implementation fidelity across states will be difficult without a neutral party overseeing the project. For these reasons, it appears advisable for an allowance for a non-state agency to apply to be the lead coordinating entity.

  16. My comments relate to # (2) Request for specific input on the Priority Section, “Are there State programs or other entities that should be added or removed from the list of required partners in order to ensure that the project can achieve the goals of the PROMISE program? If so, which ones?”

    I believe that you should add Centers for Independent Living (CILs), also known as Independent Living Centers, to the list of mandated partners. They provide a wide variety of services to assist individuals with disabilities of all ages to live integrated and self-directed lives. CILs look to remove barriers to full participation in the local community. They are private, not-for-profit organizations, and consumer-controlled (governed by a majority of people with disabilities and staffed primarily by people with disabilities). CILs are also non-residential. On an average over the last five years, the center network in New York has served 6,087 young adults with disabilities on an annual basis between the ages of 0-24 across the State. Perhaps even more important, staff and board at centers serve as role models to youth and families who are looking for direction on how to live independent and productive lives as Americans with disabilities.

  17. Because the study requires “The capacity to achieve results, including the capacity to implement the required project design and adhere to data collection protocols in order to test and rigorously evaluate the results of the project,” we suggest that University partners be encouraged and, potentially, be allowed to act as lead agencies. The PROMISE program is very much a longitudinal study and, to optimize results, should include researchers with expertise in experimental studies in each state.

  18. As a state with a smaller population, we strongly suggest that the minimum sample size be reduced. We were one of 4 states that implemented a federal Demonstration to Maintain Independence and Employment. Our total sample size for that project was 500 individuals, which proved sufficient to demonstrate significantly improved health outcomes for intervention group members over time. We have not seen the power calculations used to determine the minimum sample of 2000 people per state for PROMISE, but suggest that more sophisticated analyses such as latent curve modeling allow for greater power with smaller sample sizes.

    In addition, the information presented during the public input webinars suggested that states that collaborated on a proposal in order to obtain the required sample size would not need to have identical interventions. Requiring states to collaborate in order to obtain a certain sample size, but then allowing different interventions seems counter-productive. A more reasonable approach would be to award more projects with smaller sample sizes and budgets, with the same total sample size and budget nationally.

    Finally, we strongly suggest broadening the age range for the study from 14 to 16 to perhaps 13 to 17. Doing so would increase the sample size available in each state and, perhaps more importantly, allow for analysis of differential outcomes across a broader range of ages.

  19. On March 5th call I also asked “Foster children seem particularly challenged. Could foster agencies be sought for inclusion?”

  20. On the March 5th call I asked: With 30% parents not completing high school, can GED for parents be considered as role modeling for their children? My grandniece on TANF completed her GED & is now employed. Consider TANF reduction as outcome too. The response indicated FAMILY outcomes are important too. Remember improvements to the FAMILY could improve outcomes for the children.

  21. It needs to be clear which services are expected to be provided to the intervention group that are not already required of school districts under the transition related sections of the IDEA. What are “required” transition services and what is “above and beyond?” This will help in delineating responsibilities among partners, in particular Vocational Rehabilitation and State Developmental Disabilities officials. It will also help us to delineate intervention and control groups, without opening districts/States up to potential lawsuits. Thank you.

  22. Given the age range (14-16), it would be difficult to achieve significant employment based outcomes of these students. It would be our recommendation that the age range be expanded from 14-21, perhaps with the expectation that at least 50% of youth served are 14-21.

    Is it possible to request that a waiver be instituted for Deeming. Given the age range and the inherent poverty among parents of SSI youth, this would represent an incentive for parents to work and save while the student planning for his/her career.

  23. I am a Vocational Rehabiliation Counslor and have been programming school to work services for high school students who are deaf and hard of hearing for the past 14 years under a cash match budget. Students become eligible for programming when they become juniors (11th grade). It is always surprising to find that often the biggest barrier is not their disability but rather it is just being invited to their IEP and/or getting their parent to cooperate who fear that the SSI funding will end if their child works. Then when programming starts it seems to be often too late for them and basic independent living skills really need to be addressed first in order to be employable. (Often I see this of course in deaf adults as well due to their inability to comprehend English). Other challenges is the fact that my cash match program funding model is based on employment outcomes geared more for the hearing world and therefore these numbers are very low due to the fact that the most of the students are basically just not ready to work. Therefore there is the possiblity for the funding to be cut and wiping out the possibility of “what if”. Knowledgable parents choose a certificate of completion for their child so their education can continue until they turn 26. However it sems that would be more beneficial for many of these students to start as early as possible to get out of the classroom into life skills programming, more vocational training, community based assessments (job tryouts), job coaching, etc. in order for them to have more opportunites to become successful, independent and competitively employed.

  24. Open enrolement in our state community colleges has resulted in pre-college courses at college prices. The pre-college coarses are the end result of the student Accuplacer Assessment Scores. Students, many previously being on IEP’s in their secondary school years, are not coming from the high school with basic skills (reading, writing, math) so are not able to enter college level classes. The students are spending their grants and loan money on non-college credits and the outcome is they are leaving college with only debt. How is this helpful?

  25. First, let me begin by thanking you for the opportunity to provide such proactive feedback into the design of such an important research demonstration. I wanted to raise several general issues as you finalize your design for PROMISE, and conclude with more specific recommendations based on your request/numbering above:

    – As you are thinking about successful program measures there are a few things to keep in mind. First, given the age restrictions in the demonstration, many students may not get to a successful employment outcome—especially if there are in school till 21. Second, given the downward trajectory of work incentive utilization in the country, a potential successful benchmark might be increased utilization rates of existing work incentives. Finally, certain work incentives, such as Section 301, PASS, and Student Earned Income Exclusion, will have the unintended consequence of keeping youth on benefits over the project period.
    – To braid another important resource for ensuring student postsecondary success, SSA should consider providing a Ticket to Work waiver allowing students to receive a Ticket as early as age 18. The Ticket to Work Panel made this recommendation several years ago, although SSA never tested the impact of providing this as a potential waiver at the time.
    – I am concerned that without some sort of waiver being tested, many school districts may potentially not be interested in participating in this initiative. Use of terminology in the proposed PROMISE scope of “coordinated set of activities” is specific language used in the IDEA transition mandates which schools are required to provide to transition-aged youth already. Further, the services you highlight (e.g. case management, benefits counseling, nd and work-based learning) are all potential transition services that should be readily available to all students. At a minimum some schools are going to want this to be reviewed by their legal counsel to ensure that they are not opening themselves up to due process issues for students that are part of the control group. I recommend staying away from the terminology referenced above and including language that goes beyond what schools are already required to do under IDEA.
    – I recommend replacing the work benefits counseling in your scope. Work incentive planning is a term which more accurately represents what USDOE and SSA are attempting to accomplish. Some states, like NYS, are even moving more toward more universal language like life coaching. Benefits counseling is an old term that is representative of an era of benefits maximization, not employment maximization. Be careful what you are asking for, or you may continue to perpetuate a lifetime of dependence on benefits, with minimal earnings.
    – Finally, I am concerned about how data from smaller, rural schools will be able to be included in this research demonstration. Many rural schools may not have adequate SSI youth populations to draw from allowing them to differentiate between intervention and control groups. Is it possible to consider allowing states to do school district matching to allow treatment and control groups to be paired and matched from different schools?

    1. In regard to age of students, NYS recently completed a statewide model transition program. It specifically recognized the importance of catching a broader age range of students to see whether years of intervention had any impact. For example, do students who get the intervention later in the academic career fair as well as students who receive it earlier. At a minimum, I recommend picking up students age 17. At worst, they would only have two years of the intervention. If they stayed in school till 21, they would have four years.

    1. An issue that many state entities are going to face in applying for PROMISE is the impact of state beaucracy in being able to expedite funds in an adequate manner. Some state budgeting poses an undue hardship, as was evidenced in some states under the Medicaid Infrastructure Grants. Some states may be able to be more nimble and flexible if they could partner with a non-state entity for administration of the project–without having to go to bid which can take upwards of 12-18 months in some cases. I recommend allowing states to determine the best approach for application submission, at a minimum requiring a non-state entity to have demonstrate gubernatorial as well as a primary state agency linkage.

    2. As referenced earlier, NYS recently completed a Model Transition Program that identified specific services and supports that led to most effective postsecondary education outcomes. I recommend further exploration of the outcomes of this initiative.

    4. One concern I have is that not all states implement a rigorous program of work incentives planning (benefits counseling). It would be to USDOE’s advantage to consider centraling training on this issue for state projects.

    Thank you once again for the opportunity to provide this input.

  26. We were totally unprepared to raise an autistic son (now an adult), and the SSI was a blessing for us, to help with the additional expenses involved with meeting his basic needs on a daily basis. But, there was nothing available at the schools (other than the IEP, that was focused on covering the schools requirements only) or in the local community to help him with the complex issues of preparing him to WORK (thankfully he loves to work, and work is the primary activity to maintain his self-esteem and self-respect… without even the very basic job he has, he becomes so depressed and frustrated with his life. We still hope and pray for him to, one day, live independently, but that can only happen with an effective job preparedness system, and a school/SSI partnership could make that happen. There is nothing decent in existence, in our State, and there was nothing legitimate available for our child, when we desperately needed it (something that REALLY nurtures capabilities – not just stereotyped ideas), so lets try something for this group of kids that can be extremely productive!

  27. The economics of recovery for SSI Recipients makes it impossible for them to work, much less work their way off. SSA deducts 1/2 of gross monthly earnings over $85.00/mo., HUD Choice/Sec.8 adds 30% of their gross monthly earnings to their rent, FDA will reduce their food stamps. these govt “work penalties” , together w/ the usual work related expenses; taxes, transportation, meals, clothes, toiletries, etc result in a negative income effect. SSAs work incentives; irwes, pass plan,etc. are way above the threshold. According to SSAs own data, less than 1/2 of 1% ever work their way off. Go to http://www.economicsofrecovery.org to review our data & download the back to work budget sheet. SSAs Redbook is misleading, they combine SSI & SSDI examples. The laws have to be changed. (SSDI Recipients can work their way off.)pls do the math, it’s really not that complicated. Good luck!

    • The notice, quoted below, says we can propose waivers of authority, which should mean changing the rules. Would it be possible to have a waiver such that the work disincentive does not apply? Does anyone know?

      “In order to maximize the effectiveness of the MDPs, applicants may propose waivers of existing authorities. Waivers may apply to States, agencies, programs, children, or families. The projects should propose any waivers thought to be necessary for the successful implementation of the project. However, whether waivers will be allowed will be at the sole discretion of the relevant Federal or State agency, consistent with applicable Federal laws and regulations. For example, waivers of SSA program rules will be approved or denied by SSA. Waiver requests not currently allowed by existing law will require Congressional authorization.”

  28. Please…Please make sure that some of the participants, and their families, selected for this program are youth who are incarcerated. As the document indicated, many of the youth who receive these federal benefits are already involved with the criminal justice system at the ages 14-16. As the Department is currently developing a strategic plan regarding youth in the correctional system, it would be a disservice not to required that some of the participants selected are youth in the corrections system.

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