VIRGINIA COMMONWEALTH UNIVERSITY
March 15, 2006
PASS PROCESS, PART 2 

Captioning Provided By:  Caption First, Inc.

 
>> CONNIE FERRELL:  Welcome back for part 2 of PASS.  I know you all just went right out 
of here yesterday and looked at that case study and had all kind of wonderful ideas about it.  If 
that's not the case, if you didn't have time to really delve into it, I hope you at least got a chance 
to read through a couple of paragraphs about Sharon because I may be referring to her from time 
to time as an example.

As today we are going to pretend you are the benefits specialist with Sharon sitting in front of 
you and you are trying to figure out where to start in terms of even introducing the possibility of 
whether or not to introduce the possibility of PASS, how to introduce it and how to support 
someone such as Sharon to put together a PASS plan to submit that has a good chance of getting 
approved, more importantly has a good chance of being successful from the perspective of 
Sharon ending up successfully working in that vocational goal that she has for her future as a 
teacher.

Let's take a look at the PowerPoint slides we have to support our lecture today.  And you know 
this one, the benefit's query, we start there.  Before we are going to jump into anything in terms 
of whether Sharon looks like she is a good candidate or not for PASS, we just need to make sure 
that the information we have is correct.  And not only that it is correct, but that Social Security 
has the same information that we have and we are starting you out at the same place from 
looking at PASS and working.

So get that BPQY, make sure they have her down listed as concurrent and the amount of her 
benefits that you have listed are the ones that Social Security has listed.  And if there is 
something that needs to be corrected, go ahead and get those errors corrected first before you go 
into trying to apply for a PASS, otherwise you just have a complicated mess.

So let's take a look at the issue of PASS eligibility.  Now, I told you yesterday when we were 
looking at who makes for a candidate and who doesn't that there are some folks who are unlikely 
candidates and some that are very likely candidates.  Let's look at some different scenarios here.  
If an individual has SSI only, it doesn't necessarily mean that right now they're a good candidate.  
But they certainly can use this as a work incentive.  If you are on SSI, this is absolutely one of 
the work incentives that's a work potential for you.  Maybe not right now if SSI is the only 
income you have.  If you have no earned income, no unearned income, then you are already 
getting a full SSI check unless you have some kind of support or deemed income.

If we assume you have the full federal benefit rate, right now you don't really have anything to 
work with.  But if you are going to start a job right away or you are going to start having some 
source of income or you have some resource you can set aside, at that point when you have some 
income or resources to set aside, you're potentially a good candidate for a PASS.  If you have 
SSI only with deemed income, as I mentioned yesterday, if that parent or that spouse, whoever is 
deemed is available, is willing to pay some of the expenses associated with your PASS, then 
what was being deemed to you can then be excluded and it can push up your SSI check.  That's 
certainly a possibility with deemed or with unearned income.

I won't go back into that again today or you would kill me (chuckles).  But, again, if you run into 
situations and you are not sure how to do those, please contact your technical assistance person 
and let them help you through those cases because they are a little complex but very doable.  All 
right, what about those people that are Title 2 only.  Again, you have got to remember that PASS 
is a SSI work incentive.  You don't already have to be on SSI in order to take advantage of it.

You simply have to be eligible for SSI if some income or resources that you have were set aside.
So if you are on Title 2 only, you are not already on SSI but you may be a candidate for PASS if 
by writing the PASS and getting it approved you would then become SSI eligible.  In other 
words, you would already meet the disability test.  You already -- if you set resources aside, you 
have that out of the way and that wouldn't be a problem and you are not above SGA.  Again, 
even if an individual's working part-time and they are earning enough that they are over SGA, 
they are not going -- even if they are during a trial work period.  You say if they are on Title 2 
and during a work period, there is not a SGA test.  You are right.  But if you took some of that 
income that is over the SGA amount, right now it is not affecting the Title 2, you try setting that 
aside in the past, the person still can't get on the SSI because they can't get through the initial 
disability determination with the first step being unable to engage in SGA.

So sounds like double speak.  But if an individual is currently earning above SGA and they are 
not already on the SSI rolls, they cannot get on the SSI rolls by using a PASS to get them on, 
okay?  Now, if a PASS is written using Title 2 only, remember, that the individuals got two 
pieces of work they are going to have to do.  They will have to write the PASS application and 
submit it at the same time that they are submitting their application for SSI, okay?

And so even though the PASS is going to get approved by the PASS expert and the eligibility is 
going to be determined by the local field office, each of those parties needs to be communicating 
with one another.  So hopefully the PASS expert has a copy of the PASS as well as a copy of the 
PASS application and hopefully the field office has a copy of both as well so that they are kind 
of working simultaneously on their individual parts because each piece is contingent on the 
other.  Your eligibility SSI is contingent on approval of the PASS.  Having a PASS is contingent 
on you being on the SSI rolls.  That has to come down together, okay?

Again, remember the process of filling out an application for SSI is the same as it is for any new 
applicant you can go through the 800 line, you can go in person, you can fill out -- now you 
can start filling out applications online or at least pretty soon.

If the individual is on Title 2 only and they are going to use a PASS and by having a PASS they 
are going to qualify for SSI, those individuals do have to have a work goal that will -- when they 
meet it, result in the likelihood of Title 2 cash benefits cessation.  Yesterday, I said we need to 
kill that urban myth that to have a PASS it would have to result in you being off of the SSI rolls.  
It certainly does not.  But if you were just on Title 2 before you did a PASS, now you have a 
PASS and you are on SSI, your vocational goal has to be one that if you met it, you would stop 
getting your SGA check -- you would stop getting your Title 2 check after your trial work period 
was over and then if you kept on working, eventually, obviously, you would go off of the Title 2 
rolls.  That's an important thing to remember.

Here is Sharon.  Title 2 and SSI, that was her case, wasn't it?  PASS could absolutely, she could 
absolutely be a candidate.  There are some other things to consider but she has at least we know 
she is not going to be getting a full SSI check if she has some Title 2.  She has unearned income 
to work with.  That means she is a very likely candidate for PASS.  What about a person who has 
Title 2 and they are in 1619(b).  That's tricky, isn't it?  Because now they are not getting a SSI 
check.  How could a vocational goal make them get a lower SSI check when they are not already 
getting one?  Wouldn't that mean that if you are in 1619(b) you can't have a pass?  Not 
necessarily.  Let's say your Title 2 was so much that before you started working you were only 
getting $10 of a SSI check and you took a super small part-time job earning $150 a month and 
even though it is not very much money, it puts you over the break-even point because you only 
had $10 of SSI.  What's going to happen is that you -- if you developed a vocational goal and you 
didn't have a PASS, if you developed a vocational goal that puts you working full-time, then 
after a while you are going to lose your Title 2 check.  And then that would put you back to 
getting potentially some SSI.

It is a long story, but trust me.  If a person has Title 2 and is in 1619(b) they are not necessarily 
an unlikely candidate for PASS.  They can absolutely have a PASS.  Again, if you are not sure 
how to make that all work out, that's another one that the first time you run across that, instead of 
going they are already in 1619(b), they can't have a PASS, explore it a little further.  If you need 
help with it, contact your technical assistant folks or your PASS specialists.  They can help with 
you it.

If the person has absolutely no benefits, they are not getting Title 2, they are not getting SSI, yep, 
they may be a candidate.  If they are going to go to work or they have some other type of 
unearned income assay, veteran's benefits, those are sources of unearned income that can be set 
aside and qualify them for SSI so they may be a candidate as well.  Those are your different 
categories.

Let's say you have done that kind of prescreening.  This looks like a person that is potentially a 
candidate for PASS.  Now we have done the BPQY.  We are the same page with Social Security 
in terms of that information.  Where do we start with the potential candidate?  Start with trying to 
explain the rules and the process of the PASS.  You can go back to yesterday's handout and 
review some of those very first slides and think about how do I explain this in an understandable 
way to a layperson in terms of what the purpose of PASS is.  Go over those things.  It is not 
giving you money to pay for school or whatever it is, it is giving you money to replace the 
money you are spending out of your own money for that so that you have something to live on.
Explain the rules and the process.  Make absolutely sure the person understands the 
responsibility they are taking on once they get a PASS.  If they have to set aside the money.  If 
they find later they can't, they need to inform Social Security before they do something 
differently.  It is a big responsibility they are taken on.  They need to go in not only 
understanding how to get a PASS but also how to succeed with their PASS.

Again, we mentioned yesterday that you can use the worksheet that's part of your resource list in 
yesterday's materials to help a person work out their current expenses but also to work out what 
are going to be the expenses associated with this PASS down to the nickel.  How much money 
am I going to need each month to pay for the installment payments on this particular piece of 
equipment I have to have, how much am I going to need per semester to pay for college and 
getting to and from classes and books, et cetera.  So all of that has to be worked out literally to as 
close as you can possibly get a figure and then you maybe have to amend it as you go along.  
You need to turn all of that in.  You are looking at current expenses the person has before they 
start.  You are looking at money they are going to use that they are currently using for household 
expenses that they will place in the PASS.

You are looking at if they get the PASS approved and they have Medicaid, what will be covered 
by Medicaid.  You are looking at whether or not they have a reduced or eliminated rent 
obligation, if they have a PASS, and food stamps.  All of that goes into the calculation.  We 
mentioned that a little bit yesterday.  It is critically important because what happens sometimes is 
a person will write a PASS and it may appear, if you don't really investigate how the person may 
also recover some rental responsibility -- lower rental responsibility unless you go into looking at 
those kind of pieces, you may be submitting a PASS that the Social Security personnel looks at 
and says this is going to cut this person's money in their pocket so short that it is setting them up 
for failure and they may decline it based on it not being financially viable.  So if you can see 
together with the person that they will be saving some money somewhere else as a result of this 
PASS, you have to make sure you work those figures with the person and reflect those on that 
PASS application.  You can't expect a PASS expert to approve something based off of lack of 
information.  If it is an incomplete PASS, then more than likely it is not going to get approved in 
the way that you were hoping for.

Remember step three of the SSI calculation sheet or SSI calculation formula.  That's where you 
know what you have got to work with.  Remember yesterday, you did those calculations with 
you?  Whatever is the total countable income, when you are on step three, after you have added 
together the result of step one and the result of step two and you come up with total countable 
income, that's the amount that's taken from federal benefit rate, right?  So that's exactly how 
much you have to work with each month in terms of what you could potentially set aside in a 
PASS and recover 100% of what you set aside.  So, for instance, if the total countable income is 
$350, that individual has $350 to work with.  Now, if they don't have expenses that they need 
$350 a month, then they can say $150 or $200 or whatever.  But they can exclude up to that $350 
and get 100% of it back in the form of an increased SSI check.  So it is really important to figure 
out that critical number and then to use that to help the person to think about how aggressively 
they can save towards a goal, how much expense -- extra expense they can carry in a month and 
in some cases it doesn't make any sense to put aside $150 when you can put aside $350 and 
achieve your goal a whole lot quicker.  You just have to remember, step three is a critical step 
that gives you a critical number to help work with the person to figure out how much can you set 
aside in a PASS towards your expenses and still recover 100% and not be any worse off 
financially.
Again, remember that the Title 2 benefits are not ignored.  So it is up on the top line, it is 
unearned income on step one.  It is going to make for a higher number on step three.  But you 
have to remember if this plan is going to go on for a couple of years and it is going to involve 
working, at what point, if any, if this person was working would they stop getting that Title 2 
check?  At that point the whole calculation is going to change, isn't it?

The total countable income on step three will be a different amount.  You may be meeting with 
the person to say the first year the person is going to be saving blank amount of money and then 
once the Title 2 check stops, they will lower how much they put into their PASS by blank 
amount and use this figure instead.  So there may be stages in terms of how much the individual 
is putting into their PASS account for PASS expenses.

Again, rule of thumb, always, always, always, PASS or no PASS, you always figure out what's 
going on with the Title 2 check.  Is it there or not before you look at what's going on with the SSI 
check.  Just a reminder, can't say it enough.

Make sure that you are looking at what other benefits an individual is receiving when they are 
looking at PASS potential with a person and double-check if you are not absolutely sure whether 
or not that other program, if it is needs-based, whether or not it has a mutual understanding or 
agreement with Social Security Administration to exclude PASS funds.  So, for instance, at a 
national level, the housing and urban development agreed that if a person has funds set aside in 
the past, that they will also exclude it.  But in most states, that's the case with Medicaid but don't 
assume it.  Go and double-check because there are at least two states in this nation that Medicaid 
does not count -- they don't exclude resources set aside in a PASS.

So if you were in one of those states and you excluded funds into an account -- a PASS account, 
PASS-approved account and you got more than the Medicaid approvable for excess resources, 
you could lose your Medicaid.  So double-check, make sure that you understand your state's 
specific information, particularly around your Medicaid system and whether or not they 
recognize exclusions of PASS expenses.

Now, the last bullet on this slide, I want you to really pay close attention to.  It says add current 
monthly expenses into the past.  You are trying to figure out what a person is going to have to 
live on.  It says you can add expenses a person already has.  Maybe they have been taking them 
as an IRWE in that part-time job or maybe they didn't have anything, but they have those 
expenses related to working, fold them into the PASS for the period of time that the PASS is in 
place.  Then after the PASS is over, they would have to be able to pay those expenses ongoing.

The reason there are two asterisks in there, if you read the POMS carefully, it will say you can't 
do that.  It will say if the expense already existed prior to the PASS at the beginning of the 
PASS, it is not to be included as a PASS expense.  However, we know many examples of where 
a PASS expert, a PASS specialist with Social Security Administration has allowed for that.  In 
some cases in which they have suggested it.  So what I am telling you is, that if you follow the 
POMS to the letter, you wouldn't be adding those in.  If you follow some common practice, you 
might be missing the golden opportunity.

So I'm telling you that it doesn't hurt to look at whether or not the person has some expenses that 
could be folded in and at least have some discussion with the PASS specialist as to how they 
interpret this particular rule with the Social Security Administration.  Again, if you just assumed 
they want to approve it and you don't put it, you know they won't to.  If you put it in and follow 
the letter of the line, you haven't lost a thing but at least you tried.  I just wanted to make sure 
you understood because this slide says to do that, that you may or may not have luck with that.  
Okay?

When you are trying to think about PASS expenses and trying to think how many per month is 
an individual going to need to pay for this particular expense and how long does the PASS need 
to run, then part of determining when you would have finished your PASS is when would you 
have finished paying for those expenses and/or you started earning so much money that you now 
have enough money continue paying for the expenses if it is something like car expense.
So if the most you can afford to pay on a car payment for that modified van that Sharon wanted, 
if the most that you could be putting aside in a PASS for college tuition and van payment and 
everything is $250 a month, then you would have to look at how many months of $250 a month, 
how many months would this PASS need to run for me to pay for my college tuition and to pay 
for that van?  Okay?  And so that would help you to determine the length of the PASS.

The other thing it would determine would be how long does it take to get that degree in 
education, get certified by your state board, education board, get a job and work it long enough 
to be off probation.  So you would use both of those dates and you would look at, well, which 
one is the longest.  That's the date that you would put on your application as when you propose 
to have finished successfully completed your PASS.

What I am saying to you is it is really important, once you figured out on step three how much 
you have to work with per month in terms of what you can set aside in the PASS is then try to 
figure out how many months at that rate would I need to have this PASS in place in order to fund 
the cost associated with reaching my vocational goal.

If the expense is annual, you do the same thing.  Like in Sharon's case, you know that she had an 
annual expense of what was it?  About $5,400 for college, but about $2,700 of it is going to get 
covered by VR/PAL.  So she has a $2,700 -- now, I don't remember if it was annual or semester.  
If you have an annual figure, you would multiply it by, however, many number of years she 
needs to have of that, which in her case would be either four or five depending how long it would 
take her to get that degree done.  It might be even six if she has to take a less aggressive schedule 
of classes, which may be the case.

If there is a tuition -- if there is education expense in this particular person's PASS and Sharon is 
a good example of that, isn't she?  One of the things you want to do is look at the number of 
credit hours needed to graduate, multiply it by the cost per credit hour but don't stop there.  If 
you have ever sent a kid to college, you know that's only the beginning of it.  As a matter of fact, 
most colleges will tell you if you are trying to plan out and save for college to take the tuition 
cost and double it in order to get a more accurate cost of what it costs to go to college because 
you also have to add on top of that books and fees and possible temporary room and board.  If 
not that, you have got gas costs and lunch costs, et cetera, et cetera, et cetera.
But then you subtract out any grants or scholarships or other sources of financing that the 
individual might have.  So, again, if you were looking with Sharon, you would go straight to the 
college.  The beneficiary can go right to the educational institution they are thinking about going 
to and have a degree plan worked up.  They do them all the time for students.  They can work out 
a statement that shows estimated tuition for that particular degree plan that includes books and 
fees and a reasonable amount of extra money needed in order for a student to complete that 
degree.

So they can go, they can ask for that.  That can really help you to know what those costs look 
like and then that is your justification for how you came up with those figures.  You absolutely 
want to attach that statement on to your PASS application that you are submitting.
Again, PASS needs to be expenses that are reasonable and they need -- it needs to be expenses 
that you have done what you could to try to keep those costs reasonable.  So absolutely, the 
individual needs to apply for any grants or scholarships that they are able to apply for to keep 
those costs reasonable, particularly if you are talking about a full degree and particularly if you 
are talking about something other than a college, university or community college.  You would 
have to have a PASS going for a long period of time probably for most people in order to fund a 
full degree or master's degree or whatever you need for the entry level into your career.  If you 
don't have some sort of grant money, scholarship money, VR help, something in addition to what 
you can accumulate using your PASS, you really need more than one source.

Well, then there is the issue of vehicles.  So education expenses are a high-cost item and that's 
why you are going to put a lot of extra work in determining those costs and making sure that you 
have established why this particular educational institution is the one that you need versus one 
that's less costly and you have tried your best to keep the cost reasonable.

A vehicle is another one.  In order to have a vehicle approved, number one, it needs to be the 
least expensive way for you to get to and from work or something that's required due to the 
nature of the work that you're doing, okay?  And if -- or it is required because of your disability.  
In that case, you are looking for, and you need to do this homework -- when you say "you," as a 
benefits specialist, you are channeling this on to your client.  You are here to say I am here to 
guide new this.  I am here to provide you some advice.  I am here to provide you some support in 
this but it is your job to develop the PASS, which means it is your job to do some of this 
research.  So it is never your job to just take it.  It is not your PASS, so it is not yours to develop.  
But it is your job to help the person know how to do that.  In some cases that may mean you are 
doing 99.9% of developing the PASS but it is never your job to do it.  It is your job to assist and 
support the process.

The individual is needing to look for a reliable car or truck or whatever it is they need.  If it is 
reliable, it is relatively low miles, there is generally Social Security unless they say you don't 
really necessarily need to be getting a brand-new car.  However, if a brand-new car would be less 
expensive, then you can't rule that out.  Again, I here people say it has to be an used car.  No it 
doesn't have to be an used car.  But it needs to be reliable, the least expensive, reliable 
transportation given your particulars and your particular needs.  And many times that is a 
relatively low mileage-used car but it doesn't always have to be that.
If there is a reason why you need something that's more costly than the least cost, reliable car, 
you need to negotiate that with the PASS specialist and you can either do that by writing the 
reason right on the PASS application or you can call ahead of time and go, here's the deal, I am 
needing to spend more on this particular vehicle because VR is willing to put all the 
modifications on there but they require that the vehicle have less than 50,000 miles on it.  That 
might be a very realistic and very approvable reason for getting something that's a higher cost.  
Sharon is a perfect example of that.  She has looked at what it will cost her to get a van.  VR said 
they could do modifications but it is expensive.  She turned in a PASS and said I want to get a 
vehicle and it is going to cost me $20,000.  They might be coming back going why do you have 
to have a $20,000 one, why can't you find a good used van for $10,000 or $12,000.  She needs to 
anticipate that and either communicate that verbally ahead of time or put it down in her PASS 
that the reason she is going for this particular van is it is the most inexpensive one that she can 
find that meets the criteria needed due to her disability and due to the partner in funding the 
modifications.

Also, when you are helping a person to write down expenses achieving their vocational goals.  If 
it involves the purchase of a vehicle, remember to include the cost of securing insurance.  If the 
person doesn't have a driver's license yet, that it also includes milestones and some of the 
expenses of getting a driver's license which may mean taking a driver's ed eval.  It may include 
the cost of driver's ed and it may include the cost of getting your actual driver's license.  All of 
those would be approvable expenses.

As a matter of fact, if you have a person who doesn't have a driver's license and they are asking 
for a car purchase, unless you give them more information, you have got a PASS specialist 
thinking how in the world -- why do they need a car?  They don't even know how to drive.  You 
don't have to be able to drive to own a car, but you need to explain "I don't know how to drive 
yet, but I am taking driver's ed, I am going to get my driver's license."  Or I can't drive due to my 
disability but my mother agreed if I had the vehicle then she will drive me to and from work or I 
am going to hire a driver to drive my car to get me to and from work.  You can't expect the PASS 
specialist to be clairvoyant.  Those kind of pieces have to be added into the plan.

Have those documents showing expenses around all of those things I just talked about.  Instead 
of researching it, you are getting prices.  Going to State Farm and wherever and getting a quote 
on how much insurance would cost for that type of vehicle.  You are getting -- maybe you have 
got someone who is going to sell you a particular vehicle.  You want to get a couple other costs 
to make sure that you can demonstrate that you have looked at market value and you have got a 
reasonable price.  Many times that's a piece that gets kicked back for a person to do more work 
on.  You will have a PASS specialist that will say, you are putting down 20,000 here.  Show me 
the names of a couple other used dealerships you went do and something comparable and what 
they were asking for it so they can see you did some research, you just didn't go after the first 
vehicle that you saw, okay?

Then there is the issue of determining whether or not you want to ask for that PASS to be 
retroactive.  In other words, you can have a PASS that's approved before when you submit it.  
You can submit it saying, I want this PASS approved and I want it approved as if it started six 
months ago and I am using six months strictly as an example.  In the POMS it does not have a 
time frame that says you can't go back before whatever.  Generally you can't go back more than 
two years because that's the period of finality of reopening, if you will.  But to have it retroactive 
T would depend on whether or not you have been working on the vocational goal.  Maybe 
somebody comes in and they are already working on the vocational goal.  Maybe they are two 
semesters into college and they are having a hard time.  They are about to drop out because they 
can't afford it and they are living on SSI and a little bit of part-time income and they are just 
having a hard time making ends meet.

If they write that PASS and they had that little part-time income for the past year and they have 
been paying for college and trying to squeak by without a PASS, they can ask that PASS to be 
approved a year ago which means that if it gets approved, Social Security is going to go back for 
the past year and the income that they were counting as earned income and reducing the SSI 
check for that whole year, they will say we underpaid you for that whole last year, let us give 
you the money that we owe you.  It really is important when you are working with a person to 
look at whether or not there needs to be a retroactive date included on that PASS as to when it 
would begin.

Now, the only thing is, if they are on Title 2 only and they are writing a PASS and hoping to 
qualify for SSI eligibility, you cannot do retroactivity for a Title 2-only person.  The earliest date 
that PASS can start is the first date that they would have qualified for a SSI check which would 
be after the PASS is approved and after they have gone through the eligibility process for SSI.  
No retroactivity if you are Title 2 only before you have a PASS approved.
Well, let's assume we are all ready to write a PASS.  Sharon has come in.  She has been your 
client.  You have done the BPQY.  She wants to use this as a way to help fund her college and to 
reach her vocational goal of getting a teacher and help her fund getting an automobile.  What do 
you want to do?

When you submit a PASS, you want to make sure you tell the person right now before they even 
submit it, don't ever send something in to Social Security that you don't keep a copy of.  Because 
you are going to offer to kind of monitor a loan during the life of this PASS for Sharon, you are 
going to ask Sharon, can I keep a copy in your file as well.  Sharon has a copy, Social Security 
has a copy and you have a copy.  That way as you go along through the course of time that she is 
working on that PASS, you can go back and she is telling you, oh, gee, they increased tuition by 
15% this year, you can go back and amend the PASS.  Go back and look and see what you want 
to do and juggle a few things and contact Social Security about that.  Make sure to keep a copy 
of it.  Keep a copy of any other documents that were attached like the degree plan or whatever so 
that you have all that available.  It is going to help you to help your client more quickly when 
they run into a snag or have a question.

The PASS specialist is the one that's going to have to determine by Social Security's rules 
whether or not that PASS is reasonable and feasible.  So if the person already is involved with 
VR, absolutely you want to encourage your client.  In Sharon's case she is involved with VR, to 
write a letter saying they reviewed the PASS and it is reasonable.  Or if the PASS is a mirror 
image of the IPE then attach a copy of the IPE because the way the POMS read for the PASS 
specialist, if there is a qualified rehabilitation vocational person involved with this person that 
has okayed the vocational goals and the milestones associated with it as being reasonable and 
feasible, that the PASS specialist should not second-guess that.

So it really is in the person's best interest, if they are involved with someone of that nature, an 
EN, for instance, to absolutely make sure that information is attached because you are going to 
lower the chances that a PASS specialist would ever say, I don't think this is a reasonable goal 
for you.  I don't know how you would be able to obtain it.  Because their guidelines say if VR 
says it is so, it is so in terms of reasonable and feasible.

Now, the form that ultimately the PASS has to be on in order for it to be approved is SSA form 
number 545.  Technically the person could submit a PASS on a paper napkin.  But before it can 
get approved, somebody has got to put that onto the PASS form.  So doesn't it make sense while 
you are working with a person to pull out a copy of the SSA 545 which you have in your 
resources before you in the packet from yesterday, you have it in your core training manual, you 
have it online with the PASS, on the PASS website -- I mean on the Social Security website, it is 
all over the place.  Print it off and give several copies to the individual as worksheets, have them 
submit it already worked up.

What's going to happen it, you will submit it to the local field office and they have to get it on to 
this form and make sure that form is complete before sending it onto the PASS specialist.  If you 
want to have a big delay, send it over there on that paper napkin and wait until that claims 
representative gets around to working that up on to that form.  You have probably created a 
several-month delay in getting that PASS approved.

You know that form has several pieces to it.  You have a copy of it in your resources from 
yesterday.  And number one, on the first page right after you describe your disability and all 
those sort of things, right at the top of the first page is what is your occupational goal and you are 
going to be as specific as you possibly can, not just to work in the education field.  Sharon is 
going to be specific.  She wants to work as a teacher, elementary school teacher, if that's what 
she wants to do, with a starting salary of whatever is the going rate for a new teacher in her 
general area.  You want to be as specific as you can possibly be with that occupational goal, 
including the expected wage that you would have as a result of reaching that goal.

If the individual has a real murky goal like I just want to work, I just need to earn at least $8 an 
hour, then you either are not going to have that PASS approved or what's going to happen is it's 
going to be approved contingent on a vocational evaluation happening first to solidify a more 
specific goal.  So if you can help a person to do that piece well up front, you have really upped 
the chances that the PASS application gets approved.

And if you get right on over to page 2 or 3 in that form, you have a whole section that's asking 
the person to define each of the steps to achieve that goal.  Anything that hadn't already 
happened, in Sharon's case, if she doesn't already have a driver's license, she is going to 
specify -- it says she has been evaluated as being a good candidate for driver's ed.  She is going 
to specified taking driver's ed classes from this date to this date and achieve a driver's license by 
so and so a date.  Start classes, you will list out the different semesters.  You can just attach the 
degree plan that shows the curriculum you are going to be following.
But each of the milestones along the way need to be identified.  And she hasn't finished when she 
has obtained that degree, has she?  Her goal wasn't to get a degree, goodness, no.  Because that's 
not a vocational goal.  You don't make any money by getting a degree.  You make money by 
getting a job.  If her goal was to obtain employment as an elementary school teacher earning at 
least $30,000 a year, then you are not going to have the last milestone be finishing school.  
Instead, then, she is going to take her regulatory board exam.  She is going to start applying for 
jobs.  She is going to go on job interviews.  She is going to obtain employment by so and so a 
date.  Those are all part of those interval steps.

That PASS specialist should be able to pick that up, think about where you are right now, read 
through that step and see a logical, common sense, sequential process of how you would get 
from where you are to in that job you specified.  That's what they are looking for there, as 
objective as possible.

Again, we talked about the time frame for how long do you think it is going to take you to finish 
this PASS.  We talked about, well, if she is still just finishing up high school, we are probably 
talking six years, right?  More than likely before she is going to be in a job and off probation.  
Maybe longer.  So we are going to look at how long it would reasonably take.  We would think 
of how long it would take to cover the expenses associated with getting there and come up with a 
targeted goal for completion.

Now, some of us old geezers that were trained in this a long time ago, the time frame had to be 
no longer 36 months unless it involved an educational piece such as Sharon's and then it can go 
as long as 48.  That's all gone.  Forget 36 and 48.  That longer exists because the rules changed 
on that a few years ago.  Instead, the definable time frame just needs to be reasonable given all 
the milestones that need to be achieved and given the individual's barriers to employment.
If you have defined a time frame, let's say for Sharon, let's say we defined six years and let's say 
she gets six years out and what happened was she wasn't able to take as many classes per 
semester as she thought she was going to be able and she had to amend the PASS, maybe take 
nine or 12 hours instead of 15 per semester and it takes you an extra year.  As long as she is 
keeping Social Security informed along the way and they are amending the PASS, they can 
extend beyond the original time frame that she had identified up front.  But when they do that, 
they will extend it up to six-month increments and just keep re-uping it until she is finished if she 
is continuing to make timely progress and move it ahead.

So when a person puts down a time frame, it is not like if you don't get there by that time, they 
are going to consider you to have failed.  That's not the case at all.  It is just if it is going to take 
longer, you are going to need to communicate it and as soon as you know it and negotiate with 
them.

The next piece is really important.  Sources to be set aside.  You have to define not only what 
your expenditures are going to be, tuition, the cost of the car, et cetera, et cetera, et cetera, but 
what are you going to use?  For each of those expenditures, what's going to be your source that 
you are going to use to pay for it?  Remember, in her case she will be using probably some of the 
unearned income.  If she decides to work part-time, while she is going to school, she would have 
some earned income she could put towards it, right?  VR is putting some money into it, so there 
is another source.  Her parents may be are going to help her a little bit.  There is another source.
She wants to specify what sources she is going to be using.  And of the sources that are hers, that 
are earned or unearned income or resources that she owns, those are the ones she has asked to 
have excluded from the income and resources test.  But she still needs to give information about 
those other sources such as VR, et cetera, because otherwise it doesn't add up.  She said it is 
going to cost me this amount to go to school and I am going to be paying this amount and it 
doesn't match.  And that's something I see people do all the time when they write a PASS.  They 
will only put down the sources that are their personal sources and they won't put the others 
down.

When the PASS specialist looks at it, it doesn't make any sense.  So watch that carefully and 
review that carefully when your client is putting together their PASS application.  If there is 
major purchases, particularly if there is a car or computer, as you see in the form, there is a 
whole section that you have to do if you are going to do a car purchase.  Another section you 
have to do if you are going to do a computer purchase, that if your PASS doesn't involve those, 
you can skip right over those parts.  Just put not applicable and keep going.  In both of those 
cases or any other major purchases, what they want to know, why do you need this instead of a 
less expensive alternative, why do you need to buy it instead of rent it, how did you come up 
with this price?  Is it reasonable and compares to market price in your community and 
competitors?  Those are the pieces people need to be prepared to do if they are looking at a 
purchase of a major expenditure.

Now, there is something that's not on this slide but it is important to note and that in some cases 
Social Security will approve the PASS but they have won't approve a particular item until later.  
It is called a deferred expense.  So let's say you have a PASS specialist that says, well, I don't 
know about whether I am going to approve that car purchase.  Because I don't know if I want to 
approve the car purchase until we see whether or not you pass driver's ed.  They can do that.  
They can say I am going to approve it if you come out of driver's ed having passed.  We have got 
it there.  But in terms of starting to save the money for the car, let's just go ahead and use the 
money you are saving right now.  Pay for your driver's ed as soon as you passed driver's ed, then 
you can start saving money for the car.

In some cases they will approve it in spirit, but won't allow you to have money excluded towards 
that particular purchase until a prestep has been accomplished.  So that's what we mean by 
deferred expenses.  I know you have some information in your core training manual about 
deferred expenses and I wanted to explain that just a bit.

Again, we have already said, needs to be in writing.  Needs to be on SSA form 545 and you can 
sure as heck speed up the process of getting it approved if it goes in on that form and every 
question is answered.  If it is a question that the answer is, it's not applicable, write "not 
applicable."  Don't just leave it blank.  The more information the better.  So be prepared, benefit 
specialists, to help an individual in the development of the PASS.  But what you don't want to do 
is say, you go on home, watch your soaps, eat a few chocolate bon-bons and I will call you when 
I have your PASS ready to sign.  No, no, no.  If you think it is hard to develop a PASS, what's 
harder is working that PASS, going to school, putting all of that effort into it, finding a job, 
learning that job, showing up on your bad hair days.

That person needs to be taking ownership in this right from the very beginning.  And if a person 
is like, that's just too much trouble, I don't even want to be bothered, then you need to back up, 
explain it better, make sure they know how to do it.  But in some cases, people are just like, I 
don't want to be bothered with all that.  So you can't want it more than they want it.  And if you 
have got an individual who is not willing to put the effort forward to developing it, that should be 
an absolute cautionary flag for you.

On the other hand, if they can't do it, they don't have the skills to do it, they don't have the self 
confidence to put it together, you need to support them and stepping in and assisting them more 
hands on in putting that PASS together.

You absolutely have a role.  I am still running into benefit specialists who say benefit specialists 
don't do PASSes because PASS specialists do it.  PASS specialists can help the people.  So can 
you.  It is absolutely in your job description.  You should never, never, never tell beneficiaries 
that you cannot assist them in understanding PASS or developing a PASS.  It is absolutely part 
of your job as a benefit's specialist.  No doubt about it.

Some other people can help, too.  The Social Security claims rep can help.  Just remember, they 
have a heck of a lot of people on their caseload, most of whom are not going to work.  So they 
don't deal with this every day.  If you are really trying to expedite things and stay away from 
maybe inaccurate information, they may or may not be your best resource.  The PASS specialist, 
that's what their job is.  The work incentive liaison can be very helpful.  If you are confused 
about how to do a particular, unusual process with a PASS, you can ask the PASS specialist, ask 
the AWIC, use their input, use them as a consultant in the process.  There are a lot of different 
resources availability to recipients and beneficiaries and thinking through a PASS, developing it 
and getting it submitted.

Ultimately it has to be the PASS specialist that's a Social Security employee that approves the 
PASS and then monitors it ongoing.  We already talked about occupational objectives.  We 
also talked but I have to remind you a non-occupational objective does not make a PASS.  If a 
person's goal is not to move into a person's house and they want to save money to buy a house, 
that's not an occupational objective and the PASS will not help them with that.  It is for 
vocational goal achievement.

In addition it needs to be as clear and specific as possible.  The more specific, the higher chance 
you are going to get that PASS approved on the first run.  As much information as you can give 
on that first page where it asks the particulars about the person, about the person's age, prior 
work history, education, disability, et cetera, the more information the better.  What they are 
looking for is whether that matches up with what they are trying to do and why do they even 
need a PASS to move ahead.  Talked about milestones.  I think I gave another examples for you 
to be able to use your creativity with your clients on milestones.
They need to be objective.  They need to have time frames.  They need to be measurable because 
those milestones determines when the PASS specialist reviews the PASS.  If it is a significant 
milestone, they will review the PASS and make sure the person is still on target.
In addition we want to make sure we paid close attention to those sources to be set aside.  I 
already talked about them again before but I want to reiterate to put all of the sources, not just the 
money that the person is going to be using of their own and that you have up to that total 
countable income in step three of the calculation formula to work with.  Think that through so 
they are not overly aggressive with their saving pattern but still aggressive as they need to be to 
recover the money they need to live on.

If they are not going to keep it in a separate bank account, they have to state and show how 
they're going to be able to show the PASS specialist how they use that money, they are going to 
have to really work harder on their bookkeeping if they don't do a separate bank account.  It is 
highly recommended they set up a separate bank account to put the funds in that they are 
excluding for the PASS.  It is not absolutely required.

I hope you have gotten enough information to be dangerous about.  I think you have tinkered 
with this a little bit.  If you haven't, keep it in mind to think about how do I explain this in a way 
for my clients to understand this powerful work incentive.  Good luck to you. 

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