Plan For Achieving Self-Support
(PASS)

see other PASS Information

This incentive allows a person with a disability to set aside income and/or resources for a specified period of time for an employment goal. Monies can be set aside for a variety of expenditures, such as getting a job, education, vocational training, or starting a business. Individuals can set aside funds to purchase work-related equipment. The Plan can help a person establish or maintain SSI eligibility and can also increase the person’s SSI benefit amounts.

It does not affect the SGA determination for initial eligibility decisions. Income and resources that are set aside are excluded only under the SSI income and resources tests.

NOTE: Although the PASS is a work incentive under Title XVI (SSI), it can also benefit a person who receives Title II only. If the beneficiary is medically eligible for Title XVI but is not eligible due to the income/resource tests, a PASS may be utilized. If the person’s countable income is reduced below the FBR because part or all of it is set aside for a PASS, s/he may be entitled to a cash payment from SSI and be eligible for medical assistance under Medicaid.

A PASS is designed especially for an individual, tailored to meet his or her needs, goals, abilities and other circumstances. (The individual must be an active partner in the development of PASS.)

Any person with a disability receiving SSI that has other income including Title II and currently does not have the capability for self-support may have a PASS. People who had a PASS that did not result in self-support may try again with a new PASS with a new occupational objective.

A PASS can be made effective in any month of eligibility for SSI, or in any month of potential eligibility assuming approval of the PASS.

Anyone can help the person with his/her PASS, but it is the responsibility of the Social Security Administration to help the individual put the plan into action.

It is ultimately the responsibility of the person for whom the PASS was written or his/her legal guardian to manage and provide documentation of when, where, and how funds/resources are used in accordance with the PASS.

Utilizing a PASS can make/keep people eligible for SSI and help to retain/increase their benefit amounts. This increase will help pay for part, and in some cases, all the costs of the plan.

A PASS is not intended to subsidize a continuing level of current work activity. Nor is it intended to support a non-occupational goal such as attaining or improving self-sufficiency, independent living skills, or homemaking capability.

There is a mandatory format for a PASS. It must be in writing and include all of the documentation needed to establish a PASS (i.e.: feasible and viable occupational goals, an estimated time of completion, what money or resources are available, what income or resources are expected to be received, how the money/resources will be used, what is needed and its connection to the goal, etc).

A PASS should be for full calendar months.

• Plans are reviewed frequently for progress;
• Cases in which individuals are not currently spending funds towards the goal but are saving for a future expense will require a contract every 6 months to ensure that there has been no change in intent;
• No expenditure already in existence will be approved.

A PASS can be amended and re-approved. If the original estimate is too low, the amount of resources to be set aside can be increased at any time during the life of the PASS by amending the plan. A PASS can be approved retroactive 2 months before the approval month.

If an item or service is necessary and the cost (or fair market value) is reasonable to achieve the occupational objective, any family relationship between the provider and the individual is immaterial.

Below is an example list of expenditures. Keep in mind that this is not intended to be all inclusive. If it is necessary to achieve the work goal, it should be considered and may be approved.

• Start-up Costs: Equipment, supplies, operating capital, and inventory required to establish and carry on a trade or business
• Tuition, books, supplies, and all other fees and costs imposed by or in connection with an educational or occupational training facility including tutoring, testing, counseling, etc.
• Room and board when away from the principal residence
• Personal Assistant
• Dues and publications for academic or professional purposes
• Uniforms, specialized clothing (clothing not worn in a person’s usual day-to-day activities), and safety equipment; Operational or access modifications to buildings, vehicles, etc., which are necessary to accommodate the individual’s needs
• Medical and Social services
• Maintenance costs for any of the above
• Transportation, the hiring or purchasing of a vehicle; this can include installment payments (fuel costs are limited to only the activities necessary to attain the PASS occupational goal)
• Finance and service charges connected with obtaining any of the above
• Taxes and other government imposed fees such as permits or licenses connected to obtaining any of the above except government imposed fines, penalties, or income taxes

Taken in part from the Social Security Amendments 1972 — Section 301 Regulation No. 16, Subpart K, Sections 416.1124, 416.1161, and 416.1180-416.1186, Subpart L Sections 416.1210 and 416.1226. PPS 114, SSA 84-26.

Note: There are three points to remember: 1) If the occupational goal is feasible and the expenditures necessary, there are very few limitations. 2) This is the person’s money, and it may take a lot of time to counsel and educate the person and his/her family about the PASS. Also, the person must be fully informed of the responsibility and accountability that goes with the acceptance of a PASS. The more documentation you have, the better it will be received by the PASS specialists. 3) Resources set aside for a PASS are supplemented with SSI dollars. Be good stewards of our tax dollars.

If a submitted PASS is denied, call the SSA office and ask to appeal the decision. Ask the PASS specialists for suggested changes to the Plan.

PASS Update–EM-95-08 Dated 01/20/95

A statutory change effective 01/01/95 voided the 36/48 month time limits. Until the new criteria is published in the Federal Register, grant six month extensions upon request from individuals who:

1. Have exhausted (or will within 6 months) the current time limit;
2. Need additional time to complete the PASS;
3. Are in compliance;
4. Need to exclude additional income and resources to achieve the goal.

December 1, 1997, actions affect PASS policies, the procedures for applying PASS policies, and the overall process for handling the work associated with PASS applications and reviews. From now on:

• PASS evaluations and notices will make a clear distinction between the feasibility of the goal, based on an individual’s reasonable expectations to perform the work, and the viability of the plan for achieving it, based on the steps necessary to achieve the goal.
• Unless there is evidence to the contrary, SSA’s PASS Specialists will presume an occupational goal to be feasible, and the plan for achieving it to be viable, if any of certain State or private professionals in the field of vocational rehabilitation and employment assists in developing the PASS. If the PASS Specialist cannot approve a PASS, s/he will discuss the matter with the individual as well as with the plan’s preparer.
• Instructions regarding the limit on occupational goals will make it clear that this limit is not the strict "entry level" limit that many, both in and outside of SSA, perceive it to be. Our policy is that within the business, trade, or profession the individual has chosen, the occupational goal cannot exceed the earliest point on the career path that would generate sufficient earnings to enable the individual to pay for his/her own living expenses, uncovered medical expenses, and work-related expenses.
• Allowable expenses for major purchases will not be limited to down payments. Funds set aside for installment payments will be excluded to the extent that the expense remains related to and supportive of an approved occupational goal, and earnings do not negate the need to continue the exclusion.
• The PASS Specialist will play an earlier and expanded role in the PASS application or review, and s/he and the customer will be able to communicate directly with each other throughout the process.

 

 

 

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Pass Information
Information That Can Help You

Listed below are the six basic determinations SSA must make when deciding whether to approve a PASS. We hope this information will help you understand when a PASS is appropriate and what information you can provide SSA to help us make PASS determinations. Additionally, the PASS Specialist will evaluate the entire plan for its viability. Viability addresses the questions, "Will this plan be effective? Are all supports in place? Will the plan get the applicant to his vocational goal within the stated time and with the stated financial obligations?

Determination #1:
Is A PASS Appropriate?

Factors Which Make A PASS Appropriate

The individual with a disability is not employed and requires additional training and/or goods or services to obtain a job; or the individual is working and through training will be able to work longer hours or with less support (e.g., job coaching will be reduced or eliminated); and

The individual has income other than SSI (his/her own income or income of his/her ineligible spouse/parent(s) which is "deemed" to be his/her income or any unearned income (i.e.: SSDI, SSDAC, VA, disability private insurance payments, or excess resources (of their own or deemed) set aside to meet an occupational goal or objective); and

The expenses necessary to obtain the occupational objective will be paid for by the individual (or deemor).

Factors Which Make a PASS Inappropriate

The individual is currently receiving the full SSI Federal benefit rate (FBR).

NOTE: Because the full FBR is the maximum SSI payment, a PASS cannot be used to increase the amount of such a payment. However, a PASS may be possible for an individual without income, but with excess resources due to a goal which requires saving money in amounts above the SSI resource limit. This saved money, needed to reach an occupational goal, would not be a countable resource in determining SSI eligibility if a PASS was approved.

The individual is ineligible for SSI for reasons other than excess income or resources.

The individual does not require any additional goods or services to become self-supporting.

The individual has income, a feasible occupational objective and expenses in obtaining the objective, but a third party other than a deemor (e.g., VR) pays the expenses.

Determination #2:
Occupational (WORK) OBJECTIVE ATTAINABLE WITH SUPPORT? Is This Plan Feasible?

What SSA Needs To Know

The individual’s disability and the limitations resulting from it.

The physical/mental requirements of the PASS occupational objective.

The individual’s education, training and work history.

The availability of work for this occupation in the job market.

If the occupational objective is to work with less job supports (e.g., job coach) information is needed about the current level of job supports or hours worked and the anticipated reduction in supports or increase in hours worked once the PASS is completed.

Common Errors Associated With Occupational Objectives

The individual has already attained an occupational objective (e.g., he is currently working in non-supported full time employment and is self-supporting) and the occupational objective is a purchase (e.g., car, computer, etc.). A PASS is not intended to subsidize a continuing level of work activity.

The individual is working in supported employment and the goal will not result in less supports being needed or more hours worked.

The individual is not working, but does not need additional education/training and/or goods or services to become self-supporting in the local job market (e.g., has a marketable skill).

Determination #3:
Goal Completion Date?

What SSA Needs To Know

When the individual will complete training and attain the stated occupational goal.

When the individual will make the final payment for approved PASS expenses.

Common Error Associated With The Goal Completion Date

Routinely showing 18 months from the PASS start date as the date of completion of the goal. In many instances, 18 months has been shown instead of the actual date the goal would be attained because SSA operating instructions allow us to initially approve a PASS for only 18 months before conducting a compliance review. The time limit SSA uses for initially approving a PASS is an internal SSA control and is not the length of time that should be used to determine the PASS goal completion date. (Effective with 1995 changes, compliance reviews are conducted at 12 months or sooner at the discretion of the reviewer.)

Determination #4:
Are The PASS Expenses Both Necessary And Reasonable?

General

What SSA Needs to Know

The specific expenses required.

The necessity of the expense. Can the goal be reached without this expense?

The reasonableness of the expense. Can a less expensive alternative still allow the individual to achieve the goal?

Common Error Associated With Pass Expenditures

Listing items such as "computer plus software," "automobile," etc., without providing specifics (type, model, etc.) and/or documenting the necessity of the item in achieving the goal.

Automobiles
What SSA Needs To Know

Specific year, make and model.

If a new automobile is being purchased, an explanation why purchasing a used car in good condition is not a reasonable alternative.

If the individual already owns a car, but indicates it is no longer reliable and proposes selling it and purchasing another vehicle, they must justify that this purchase would be a more reasonable alternative than repairing their current vehicle.

The availability of public transportation. SSA can only approve an automobile expense if public transportation is not available/ reliable or cannot meet the individual’s needs (e.g., buses do not have a wheelchair lift). A complete statement must be provided explaining this issue if an automobile is a listed PASS expense.

The cost of fuel (to and from work or the training site), insurance, maintenance and other fees related to operating a vehicle.

Common Errors Associated With Automobile Expenses

Listing the purchase of a new or used vehicle as a PASS expense without considering other modes of transportation or the feasibility of repairing the vehicle the individual currently owns.

Listing the purchase of an automobile as a PASS expense when the primary need for a vehicle is to conduct daily activities rather than for a work related need (e.g., public transportation is available to the job site, but is not available to go to the grocery store).

 

Computers
What SSA Needs To Know

The type of computer, software and peripherals needed and the cost of each item.

Documentation regarding the necessity of the particular computer, software, and peripherals to achieve the occupational objective.

The type and cost of computer training required by the individual to use the computer to reach the occupational goal.

Common Errors Associated With Computer Expenses

A computer and software are listed as PASS expenses without information regarding whether the employer will provide computer equipment and training to the disabled individual.

Software packages are listed as PASS expenses, but there is no explanation given why the specified software is needed to perform the job.

PASS Preparation Fee
What SSA Needs To Know

A breakout of the services provided by the organization preparing the PASS, the amount of time spent preparing the PASS and the amount charged per hour.

Proof of payment if the individual has already received and paid for these services.

Common Error Associated With PASS Preparation Fee

Charging a flat fee regardless of the amount of time or type of services provided to the client. The charge should always be itemized.

Medical Expenses
What SSA Needs To Know

Why the medical treatment and/or medication is needed to achieve the stated occupational objective.

Who is currently paying for the medical treatment.

Common Errors Associated With Medical Expenses

Listing medical expenses as a PASS expense when a third party (e.g., private insurance) pays the medical provider or reimburses the individual. Only non-reimbursable out-of-pocket expenses are valid PASS expenses.

Medical expenses are listed on a PASS over the entire period the PASS is in effect, but Medicaid will pay the medical expenses once the individual is eligible for SSI.

Food And Shelter
What SSA Needs To Know

The cost of meals consumed during work hours (e.g., lunch).

The cost of clothing for a job interview or to get started at work, and/or uniforms and specialized clothing specifically required for the job.

The cost of shelter expenses necessary to achieve the occupational goal. (NOTE: Shelter is a valid PASS expense only if it is an additional cost a disabled individual incurs while away from his/her principle place of residence for the sole purpose of attending educational, training, employment, trade, or business activities.)

Common Errors Associated With Food And Shelter Expenses

Listing shelter (e.g., an apartment) as a PASS expense when it is not an additional cost incurred in achieving the PASS goal.

Listing ordinary living expenses (e.g., food, utilities, etc.) when these expenses are not additional expenses related to achieving the PASS goal.

Education/Training
What SSA Needs To Know

The education/training requirements for the occupational objective.

The number of courses needed and the length of time the individual will need to complete the course work.

If a degree is required, the number of courses the individual has already taken which can be applied toward the degree and the courses that are still needed to earn the degree.

The cost of tuition and other related fees.

Common Errors Associated With Education/Training Expenses

Failure to provide the complete educational/training background of the individual.

Insufficient information to justify the need for an additional educational degree or training program when it appears the individual’s level of education/training is adequate to become self-supporting.

Determination #5:
How Will The Individual Pay For Usual Living Expenses And Pass Expenses If The PASS Is Approved?

What SSA Needs To Know

The source and amount of income available to the individual to meet his/her ordinary living expenses and pay for PASS expenditures.

Common Errors Associated With Living Expenses

Listing PASS expenses which equal the disabled individual’s income (e.g., $850.00 per month Social Security benefit) and not explaining how the individual will be able to meet usual living expenses with the SSI payment when it currently takes the entire $850.00 each month to meet living expenses.

Determination #6:
What Is Your Business Plan?

What SSA Needs To Know

Social Security needs to see that the business you are proposing is likely to increase your income. Many PASS proposals are for enterprises that are really hobbies, rather than profit-making businesses. The business plan will show SSA how exactly you intend to make a profit. To prepare a worthwhile business plan requires a great deal of effort. The rewards are great, not the least for the entrepreneur. It will enable you to see what you are actually proposing and foresee potential problem areas. You should prepare your business plan with the same accuracy and thoroughness, as if you were requesting a loan from a bank. In this case you are "borrowing" from the U.S. taxpayer.

Self-employment is very demanding and many new businesses close down every year. Explain why you believe that operating your own business is more likely to result in self-support than if you worked for someone else.

Your Business Plan Must Include The Following Information

• Business name, address and the owner’s name.
• Business form (sole proprietorship, partnership).
• Description of principle activity, and product or service to be provided. Include objectives of the business and timetables for establishment of the business and attainment of objectives.
• Explanation of start-up (new start-up, purchase existing business, or franchise).
• Explain why it should succeed. Your explanation may include anything unique about your business or your background in the area, which will contribute to your success.
• Describe the market for the product of service. This is extremely important. If there is a market for your product or service, it can be measured. This cannot be a guess; it must be based on research.
• Describe advertising plan to reach the market and sell the product.
• A list of employees and their functions and qualifications.
• Description of your financial plan including anticipated expenses (e.g. payroll, supplies, equipment, taxes, utilities, insurance, etc.). Include profit and loss projections for the duration of the PASS and at least on year beyond its completion.

Often it will be necessary for an individual to take a class in starting a new business through an organization such as the Small Business Administration in order to prepare a business plan.

Common Errors Associated With Self-Employment

Proposing a hobby as a business. If you want to be a desktop publisher, for instance, you must show through your market research that your business will generate enough income to replace your SSDI, if you are a Title II beneficiary only before your PASS.

Failing to submit a business plan. This takes work but will repay your effort.

Failing to project sufficient profit to eliminate SSDI benefits or to reduce SSI benefits significantly.

Failing to realize that expenses used to reduce net income for tax purposes cannot be used as a PASS expense.

Requesting an infusion of PASS money for an already existing business.

 

 

SSA Work Incentives Home Page || Alphabet Soup || BWE vs. IRWE || Calculator || Regional Technical Support || Encyclopedia || FAQ || Feedback || Forms || Resources || SSA || Title II || Title XVI || WI Liaisons || WI Comparison Chart || Ticket To Work || Did You Know?

Sponsored by RCEP7,
University of Missouri-Columbia
& RegionVII PASS Cadre

Site Design by Missy Lange