April 22, 2009
VCU Webcast


Services Provided By:  Caption First, Inc.


   >> LUCY MILLER:  Hello, everybody.  I'm so glad that all of 
you could join us for this Webcast today on wage reporting for 
beneficiaries of the Social Security disability program.
    
   Many of you may have thought, it's an odd topic to do a 
Webcast on.  But it is a topic that is really critically 
important.  There are so many problems that beneficiaries can 
get themselves into, when they don't report their wages at all 
or when they report improperly. 
   
   Let's take a look at some of the things that are importance 
of wage reporting.  First of all, failure to report wages 
causes literally more problems for the people that we work 
with in WIPA projects than any other single issue.  Any of you 
CWIC sitting and listening to this know that is the case.  How 
many times do beneficiaries come to you about to take a job, 
and we find out that there is past wages that are unreported 
or undeveloped, or people that are in a massive overpayment 
situation, because they failed to report wages and Social 
Security found out about them later. 
   
   I think sometimes we assume that beneficiaries know what 
they are supposed to report, and how to report it.  And 
nothing could be further from the truth. 
   
   It seems like you would know you have to report wages, but 
for a lot of people, they think that when they get a paycheck, 
and that FICA is taken out, there is an assumption that there 
is an automatic sharing of information within the Social 
Security Administration.  You will often hear beneficiaries 
say, well, they were taking that FICA out of my paycheck, I 
assumed that they knew I was working and that they would have 
all the data about how much I earned. 
   
   Doesn't work that way.  Those of us who do benefits 
counseling for a living always see the result of that 
assumption.  The problem also is even when we tell 
beneficiaries to report, we have to tell them more than, you 
need to report.  They don't know what that means.  They don't 
know how to go about it.  You can report by calling the 800 
number.  That is one method we wouldn't recommend or you can 
report by sending written statements of earnings into the 
local field office.  One of those methods leads to trouble 
where there is no documentation that you reported, the other 
method is useful, and there is written documentation 
indicating that you did in fact report.
    
   Information even when our beneficiaries report the 
information and report it properly, using appropriate 
procedures, unfortunately the Social Security Administration 
personnel are awfully busy and that information isn't always 
acted upon quickly.  It isn't enough to just report.  
Beneficiaries have to watch their payments, watch the 
correspondence, follow up as often required to make sure that 
the information provided is actually acted upon.
    
   And I think another assumption is that our beneficiaries 
say, I reported it, and I kept getting a check.  Yeah, I know 
my earnings were really over what they told me I should have, 
but I figured they knew what they were doing.
    
   There is a lack of understanding of how enormous the Social 
Security Administration is, and how much time and energy it 
involves to enter all of this data.  You really have to teach 
beneficiaries to be better advocates for themselves and to 
know, to be watching what should be happening to my check.  
Watch that check to make sure that those effects really are 
being seen.
    
   All of us who do this for a living know that failure to 
report earnings or in the SSI program any other kind of 
accountable income can cause serious overpayments.  Many of 
which are thousands and thousands of dollars.  These 
overpayments are a burden for the beneficiaries and they can 
be a burden over years.
    
   Now, there is certainly ways to forgive an overpayment, 
particularly in the SSI program.  But we should not assume 
that overpayments can be forgiven, or even negotiated readily.  
It's a whole lot better if we can avoid the overpayment to 
begin with. 
   
   That really leads us to this whole notion that a lot of what 
you are doing is an ounce of prevention.  You do a lot of 
curing and that is wonderful but prevention is the way to go.  
Let's not misunderstand.  You CWICs, folks who work for WIPA 
projects, you are not responsible for providing wage reports 
yourself.
    
   It's not your job to call Social Security or to send letters 
in, writing down what people have earned.  We certainly can 
facilitate that.  We can support it.  But it's not something 
that a CWIC should be doing independently. 
   
   A huge part of your job should be teaching beneficiaries 
proper wage reporting techniques, and monitoring that to make 
sure that they really are following it.  It isn't enough to 
just tell the social -- the beneficiary, just report this.  
Because they don't know what that means.  There are certain 
techniques that are more successful than others.  And it 
really does involve very planful and overt teaching.  That is 
something I think sometimes we are not really doing as much as 
we should be.
    
   Another aspect is not just reporting wages but reporting the 
usage of work incentives.  Any CWIC knows that that is a huge 
part of your job, helping that beneficiary develop an 
impairment related work expense, helping them understand that 
tracking the expenditures by keeping receipts and making sure 
all the documentation is in order is critically important as 
well.
    
   And that again, that the part of our teaching role, but also 
a part of our active supporting role, where you might be 
checking with a beneficiary on a periodic basis, are you 
keeping all of your receipts for your transportation?  
Remember we have claimed an IRWE, when you have your 
redetermination in the SSI program, they are going to need to 
see that or when that substantial gainful activity 
determination is made, Social Security is going to need to 
check those receipts at that time as well.
    
   It isn't just reporting wages.  It's reporting anything that 
will reduce countable wages or affect the amount of wages that 
we count against a beneficiary. 
   
   Finally, once those reporting skills are taught, it isn't 
enough to just tell the beneficiary to go off and do it.  With 
some people we really do need to keep checking.  Under the new 
WIPA paradigm we have a much broader role in long-term follow-
up with beneficiaries, and part of what we need to be checking 
on is, did you report your wages?  How did you do that?  Did 
you keep a copy of the letter that you sent in?  Where is it?  
Have you kept your receipts? 
   
   All of that, just making sure that everything has gone well, 
to avoid that overpayment that could occur from failure to 
report. 
   
   Let's look at the differences between wage reporting for 
individuals who get a Title II disability benefit, and you all 
know what those are, SSDI, CDB or childhood disability 
benefits, and DWB or disabled widows or widowers benefits.  
Those are all of the programs that disability benefits that 
are authorized and afforded under Title II of the Social 
Security act. 
   
   Let's take a look at that first.  Then we will move on to 
the SSI program.  A very simple rule when you are reporting, 
it's just to remember that in the Title II program, a good 
time to report is whenever you would expect a change to be 
caused by the wages. 
   
   You see a list here of some of the events that might cause a 
change in situation.  The use of a trial work period service 
month, so if a beneficiary is earning over the current trial 
work period figure, you would want to start reporting those 
months where you are actually using those valuable trial work 
period months.  Certainly, at the end of the trial work 
period, we hope you are tracking that, when it is concluded, 
remember that an important activity takes place. 
   
   This is where Social Security should be checking the 
beneficiary's earnings to see if SGA, substantial gainful 
activity, is occurring.  So it is critically important that we 
report wages again at the end of the trial work period.
    
   Now, it doesn't say this on the slide but I want to make 
sure that you remember, at this point, there is another type 
of reporting in the Title II program, that is essential.  That 
is to fill out that work activity report.  Now, that is a form 
820, or an 821, depending on whether the individual is in wage 
employment or self-employment.  It's more than just sending in 
the pay stub.  This is where you are literally describing the 
work activity.  You are identifying any special supports the 
individual receives, giving clues to subsidy which is a work 
incentive, impairment related work expense, unsuccessful work 
attempt, any of those tools that that claims rep has in their 
toolbox to make a proper SGA determination, there should be 
clues to that written in the work activity report.
    
   Of course, if an individual is engaging in SGA level work, 
you want to make sure that that is noted by Social Security at 
the end of the trial work period, or whenever it occurs.  And 
that the payment is stopped, is ceased, in a timely manner.  
Many cases, you will report and report, and that check keeps 
on going.  We have to make sure beneficiaries understand, you 
are getting checks that you are not entitled to.  Let's not go 
spend those.  Let's put those in the bank, let's make sure 
that we have sufficient funds to pay these back when Social 
Security gets all caught up, and notices when the actual 
checks should stop. 
   
   Another time that is very important that wages are reported 
timely is during the extended period of eligibility, after 
that SGA determination has been made, and cessation month and 
grace period has occurred, that three-month period you are 
allowed to get that check.  Remember that after that, in the 
EPE, individuals are allowed to get a cash payment for any 
months where their countable wages are above the current SGA 
limit, I'm sorry, below the SGA limit and their payments 
should not be received in months where their earnings are 
above the SGA limit.
    
   This takes some very careful tracking.  And it's something 
we need to be teaching beneficiaries, looking at those pay 
stubs to make sure that they are being submitted, tracking it 
carefully on that trial work period/SGA tracking chart, which 
all of you WIPA personnel have been trained to use.  So you 
know which months was the payment due, which months was the 
payment not due.  You can keep track of that and make sure 
everything goes well. 
   
   Certainly, that last bullet there, the need to reinstate 
payments, either during the EPE or even afterwards, you have 
to make sure that you are sending in those pay stubs, 
reporting that information, so that the check is started 
again. 
   
   There are some challenges for Title II beneficiaries, that 
make proper reporting and having those payments effective 
properly really kind of difficult.  And that is that the first 
thing people don't really understand is that if you are 
working at say 200 or $300 a month, that level of income is 
below even the trial work period guidelines.  That doesn't 
cause change in your Title II check at all. 
   
   You can report those wages, and probably should report them, 
but nothing will happen.  No trial work period months are 
used.  No change in the check obviously occurs.  That can be 
kind of hard to communicate to a beneficiary.
    
   Yeah, it's not going to affect your check but you still need 
to report, you still need to report.  The second point is in 
the Title II program and many of you know this, trial work 
period and particularly SGA determinations require that Social 
Security look back over a period of past work, in order to 
find a pattern, you can't really figure that out in realtime.  
You have to look backwards in time.  So if your beneficiary is 
reporting on a monthly basis, doesn't really lend itself well 
to this sort of retroactive looking to see a pattern. 
   
   Actually, it's better in this system to hold those wage 
reports until a decision like SGA is being made, and submit 
all of that in one fell swoop, so that that pattern can be 
seen if it exists. 
   
   That is kind of hard to get a beneficiary to understand.  
Remember too in the Title II program that Social Security is 
not looking at what income was paid.  That is the way it's 
done in the SSI program.  They are looking at when was the 
income earned.  My goodness.  That can create some problems. 
   
   Remember people that are paid later than the income is 
earned, people that are paid on different systems that don't 
correspond with when the income is earned, this can create 
some real problems.  So when we teach beneficiaries about how 
to track their wages, we have to let them know it's not when 
you got paid.  It's when did you earn it.  When was the work 
performed that generated this particular income for you. 
   
   Different field offices also will use different processes.  
And for those of you who work with numerous field offices, it 
is not uncommon to have a work incentive liaison tell you to 
follow one procedure in one office, where another office down 
the road prefers another procedure. 
   
   There are variances in preferences.  CWICs need to be 
asking, what is your preference?  How do you like to have 
wages reported?  For Title II beneficiaries, some offices do 
want the monthly wage reporting.  In other offices, they are 
going to say, can you not worry about it until we get to the 
end of the trial work period?  And then just make sure that we 
have all of that past data and the data moving forward.  You 
need to find out what is the preference in that office and 
follow whatever directions you are given.  Don't assume that 
everybody does it the same.  That is not the case. 
   
   Remember too that you can report and report and report, but 
it really only matters if the claims rep has taken the time to 
develop the work history, to verify those earnings, and to 
adjudicate it.  That means, to make those determinations like, 
yes, the TWP month has been used here and here and here, or 
no, SGA is not occurring.  There is no pattern of SGA level 
work.  Those are the determinations that the wage reports you 
are sending in are supposed to lead to.
    
   If you are reporting diligently and no one is paying 
attention, that doesn't do anybody any good.  Sometimes we 
have to rattle the cage a little bit, and make sure that those 
determinations are made. 
   
   What can you do to help in these situations?  First and 
foremost, CWICs really, really need to have a close 
relationship with their local field office.  They need to know 
that will on a first-name basis.  They need to know what 
procedures are preferred, how that local office wants things 
done.  There is no quicker way to make an enemy than to simply 
disregard whatever the field office staff is telling you to 
do. 
   
   We need to make sure that we are being helpful, not a 
hindrance in terms of their ability to develop that work 
history and make decisions. 
   
   Stressing that responsibility to report is so critical.  Our 
beneficiaries sometimes think that it's someone else's job.  
Maybe they believe it's the CWIC's job.  Maybe they think 
Social Security just knows that they are working and what 
their wages are.  Sometimes they think, well, it's my rep 
payee that is doing that or my case manager.  Unless we are 
checking and verifying, we don't know.  And who ultimately is 
going to suffer for failure to report isn't the rep payee.  It 
isn't the case manager.  It's the beneficiary.  It's their 
check. 
   
   So we have to make sure that they understand their 
responsibility, and keep them informed and keep them on the 
ball in terms of checking to make sure that that check they 
received is rightful, that it was supposed to be received. 
   
   Teaching people to keep those records, you know, it is so 
important that we take the time to teach.  There is the old 
expression about fishing for someone and you catch a fish for 
them and you feed them for a day, but when you teach them to 
fish, you feed them for a lifetime.
    
   There is no clearer proof that this saying is true than 
reporting.  We have to make sure that beneficiaries understand 
what has to be done, that what documentation needs to be kept.  
All of those receipts, let's keep them in that shoe box or 
that file folder and we know where that is, and that we keep 
these until the time that Social Security needs them to make 
that determination, whatever that might be. 
   
   Something I think we forget about is that we look at the 
paperwork that's involved in the WIPA system, and we kind of 
look at that as something Social Security makes us do and it 
doesn't have any bearing on my job.  Well, that is not true.  
The WIP which is the work incentive plan is really your to do 
list with that beneficiary, and you can use that WIP, very 
successfully, to structure reporting periods, reporting time 
frames, for beneficiaries.  You can also use it to hold 
beneficiaries accountable, so that when you are updating that 
WIP, you say, okay, you told me you were going to have these 
receipts kept, you were going to have these pay stubs.  You 
were going to mail everything in, by this date.  Have you done 
it?  Where is your documentation that you have done that? 
   
   Don't just look at the WIP as a useless piece of paper work 
to satisfy your funder.  It truly is something that if you are 
doing it properly, is an aid to you in your job.  It is not 
just a hoop that you have to jump through.
    
   Then of course, proactively following up, we have said it 
about 17 times, just in the first few minutes, but it's 
critical.  You can't just assume people are going to do this.  
You have to be checking.  Then you have to be looking to see, 
did Social Security actually act on that information, or have 
they not gotten around to this yet? 
   
   That leads into this slide, how do you check?  I'll tell you 
the best way I know to check is using that invaluable BPQY.  
You know that stands for benefit planning query, and it's a 
report that we request from Social Security, that shows us a 
whole lot of things.  It shows usage of work incentives.  It 
verifies benefits for us.  But a really important thing that 
we can see on the BPQY is, what Social Security knows about 
the work history of the beneficiary.  Because that's going to 
show on the BPQY.  The BPQY is a report that pulls from a 
variety of data systems, and if you have been reporting, and 
that information hasn't been entered or hasn't been developed, 
the BPQY is going to show that. 
   
   Well, let's look at some things you could see on that BPQY 
that should send some red flags up, that should say, past work 
history existed but it's not showing up.  First of all, your 
beneficiaries typically know, oh, yeah, I had a job and it 
lasted from this long to this long, or yeah, I worked at this 
place.  They are going to tell you those things.
    
   And if you have done an appropriate intake, that data is 
going to be written down, at least rough information that the 
beneficiary gave you.  So if your beneficiary is saying, yeah, 
I worked several times since I got on benefits, you get that 
BPQY and at the bottom of the second page of the BPQY, you see 
no wages listed, you've got a problem.  That means that this 
work either wasn't reported or if it was reported, it was 
never entered into the system or never acted upon. 
   
   Here is something that you will see often.  You know, Social 
Security does an interface with the IRS roles, a lot of our 
beneficiaries don't understand that, but they do.  They do 
have access to that data.  And it will show on the bottom of 
the BPQY, when you see annual, annualized amounts like a year 
listed, and then like a large amount of wages at the bottom, 
that's being pulled from an IRS interface. 
   
   What is interesting, April 15 was just last week, many of us 
know, what's taxable isn't the same as what Social Security is 
interested in, in terms of earned income.  Interest income is 
taxable.  Rental income is taxable.  All of that is going to 
show on your taxes.  All of that is going to get dumped into 
the BPQY when Social Security does an interface.
    
   Maybe I'm showing that I paid taxes on $30,000 in a year.  
That doesn't mean that all of that was earned income.  And 
it's earned income that Social Security is interested in the 
Title II program.  So when you see that total amount at the 
bottom, and it doesn't match the wage data that the individual 
is reporting to you, or that Social Security is showing, 
particularly if the wage data is much higher, you've got a 
problem.  You are going to need to push that a little bit 
further. 
   
   That third bullet on your slide here is exactly the same as 
that when you have annual income showing, but you have no 
monthly breakdown, there is no V in a parentheses after that, 
that means that the wages have not been verified, which means 
in the Title II program, a month by month breakdown hasn't 
been performed, and if you just have annual data, how do you 
know which months were actually TWP months?  How are you able 
to really know if SGA has occurred?  You can't. 
   
   So, that is an indicator that some research needs to be 
done.  Further development needs to be done. 
   It's very common to show very high annual income, again 
because of the IRS interface, but under the section that says 
TWP months used, it's blank.  Well, that is a red flag.  That 
should tell you that CWIC that these, the data that you have 
sent in, has not been adjudicated.  Nobody has looked at that 
to see, is it sufficient to trigger a trial work period month?  
And which month did that work actually occur?  And how many 
trial work period months have been used, heaven forbid, maybe 
all of them have been moved and you have moved into the 
extended period of eligibility. 
   
   This BPQY can tell you where the problem areas are, and when 
we see the problem areas, we need to push further.  We don't 
ignore that.  We work with the beneficiary.  We show them the 
BPQY.  We say, this is what they are showing.  Does this match 
your recollection?  Then we have to help the beneficiary 
gather the month by month breakdown of those wages and get 
that into Social Security, so that TWP months can be tracked 
appropriately, and SGA, if it's occurred, can be determined 
and the checks seized appropriately. 
   
   Let's switch gears.  You guys all know that the Title II 
program is one thing and the Title XVI program or SSI is a 
horse of an entirely different color. 
   
   This program very much needs month by month wage reporting, 
because unlike Title II, where your check remains the same, 
you either get all your checks or none of your check.  In the 
SSI program, you are allocated a payment based on exactly how 
much income you had that counted in that month.  To make 
matters even worse, you all know, earned income is not the 
only thing that counts.  You have all kinds of stuff in the 
mix here.
    
   You have to make sure that beneficiaries know what needs to 
be reported.  And if you think that SSI recipients have any 
idea that all the different things that need to be reported, I 
hate to tell you this but you have got another thing coming.  
They don't. 
   
   So it's very useful to actually provide them with a list.  
Now, in the packet of materials that we provided you, we gave 
you a handy little document to use with beneficiaries, that is 
entitled, "tips for reporting income to Social Security." Or 
reporting tips, something like that. 
   
   On that little document is a chart.  It lists the things 
that a beneficiary needs to report if they get Title II 
disability benefits and/or if they get SSI.  It's really 
important that you print that off, give it to the 
beneficiaries, every beneficiary that you work with who is 
going to go to work, and you literally review that with them 
in a very planful manner.  You go over all the tips that are 
in there.  If nothing else, you go over that chart that says 
these are the different things that can trigger a change in 
your SSI payment that you have to make sure Social Security is 
aware of. 
   
   Monthly income, does affect the SSI cash payment amount.  
So, income changes need to be reported promptly. 
   Now, here is an interesting fact.  Different field offices 
have very different preferences about reporting in the SSI 
program. 
   
   Now, we all know that exactly how much you got paid or 
received in a month is what is used to determine what your 
cash payment is or what you are due for that month.  The 
problem is, for people that have widely varying jobs or 
amounts of income, people that work on an hourly basis, and 
the service industry, restaurants, Wal-Mart, places like that, 
you know that one month you may have a lot of hours at work, 
whereas the next month you may have very few. 
   
   Your wages are going to fluctuate.  When that happens, it's 
a lot easier for everybody if Social Security simply estimates 
the amount of monthly wages, and uses that estimate forward, 
until the redetermination that occurs every calendar year. 
   
   Now, some field offices don't want to estimate.  Some really 
do want that monthly report, that those pay stubs to be sent 
in every calendar month, so that they can generate that letter 
and adjust that check. 
   
   I will tell you that the preference for the monthly 
reporting is the minority would be my guess.  In most cases, 
the field offices will prefer estimation.  It's just much 
easier for everyone.  And literally it's much easier for you 
and the beneficiary.  Now, when you estimate earnings, you 
need to be careful that you are not estimating too low, 
because if you do that, when you come to redetermination time, 
Social Security goes backwards, takes the actuals, figures out 
what everybody should have gotten and you can either owe money 
or they owe you money.  I would much rather be in the position 
of getting a lovely windfall from Social Security than owing 
them money which then comes out of my SSI check or where I 
have to write them a check. 
   
   So estimation, we should not view that as a bad thing.  That 
is a good thing.  We just have to help the beneficiary come up 
with a solid estimate, and then if it's significant change 
occurs, they become ill, they are laid off, their hours are 
reduced, then we need to report that to Social Security as 
well.
    
   In some cases, monthly wage reporting actually can cause 
confusion, when Social Security enters the data, it generates 
a letter, and if you are reporting every month and things are 
changing every month, you get this really awful stream of 
letters, oh, we owe you this for last month, oh, wait, next 
month, we should have paid you this but we paid you that.  And 
it is just cacophonous.  So when possible, ask if estimation 
is allowed and if it's preferred, and by all means, use that 
as a, more comfortable system for everybody involved.  That 
way your beneficiary will get a nice little windfall if you 
plan things well at the end of the year, rather than the yucky 
letter saying, you owe us, however much. 
   
   Now, what are the ways to report?  Basically, a report needs 
to be done in writing.  I'm going to actually break that rule 
because there is a new automated wage reporting system that is 
telephone oriented.  You can do it over the phone.  It's a 
lovely addition to the options that you have. 
   
   I'm going to talk about that in a minute.  If you are going 
to use more traditional method you recommend not verbalizing 
that.  Don't call your local field office.  Don't call the 
main Social Security toll-free number and make sure the 
beneficiary knows not to do that either.  You are better off 
by capturing whatever the change is related to your earnings 
status in writing.  And you know us at VCU, a form for 
everything.  In your packet you should have gotten a form that 
we recommend you use, certainly isn't required.  It's also in 
your WIPA training manual and I believe it's on our Website as 
well.  And it's called a notice of change in earnings status. 
   
   What that means is, any change in an individual's earning 
status can be captured on that form, and it can be used for 
Title II or Title XVI SSI recipients.  It is a very open and 
flexible form.  You can save that in Word format as a 
template.  Every time you have a beneficiary you are working 
with, you can teach that individual to complete that form 
either in handwritten or on the computer, or you can complete 
it.
    
   You just can't mail it in without the beneficiary and/or 
their rep payee paying it because otherwise it's just a third 
party report which Social Security has to verify with the 
beneficiary anyway. 
   
   But you can certainly help fill that form out, as long as 
that beneficiary signs it.  You can mail those into the field 
office.  I love those.  You keep a copy.  It's in your file.  
You give one to the beneficiary.  Then we are all covered on 
our bases in terms of proving that you did fulfill your 
responsibilities for reporting.
    
   You can Fax those in.  Many field offices prefer Fax to 
mail.  You can address that to a specific human being, whether 
that is the claims rep assigned to this person or the work 
incentive liaison.  Again, check with your field office.  They 
have different preferences.  Or, last case scenario, you can 
certainly hand-deliver these kinds of things to the Social 
Security Administration. 
   
   The last bullet here is something new.  You can now submit 
wage information for SSI recipients, using an automated 
reporting system. 
   
   And I believe it's using a toll-free number, it's a 
different number than the main toll-free number.  It's the 
only phone reporting that we would recommend.  Again, we don't 
recommend calling the local field office on their local 
number, or using the national toll-free number, just the 
general information number, for reporting.  And of course, by 
all means, you have to drill it in, drill it in, we keep 
copies of everything.  Beneficiary keeps a copy.  The CWIC 
keeps a copy.  It's another reason why sometimes it's easier 
for us to actually develop the form, because we've got that 
copy machine around the corner.  Most beneficiaries wouldn't 
have that. 
   
   All righty.  Let's take a look at this brand spanking new 
automated wage reporting system.  This reporting system, you 
got to love the acronyms here.  The full name is, the SSI 
automated telephone wage reporting system, or, SSITWR.  My 
goodness, what a mouthful.  Basically this is a special toll-
free number that beneficiaries can use, and it has one purpose 
and one purpose only, and that's to report wages. 
   
   Not other forms of income, wages.  It's a fully automated 
system.  There is not a human being to talk to on the other 
end of the phone.  Now, there is positives to that and there 
is negatives to that.  But it is fully automated.  Now, this 
does not work for beneficiaries who have special work 
incentives, with one exception.  I'll show you in a minute.  
If an individual is using a PASS, if they have impairment 
related work expenses or blind work expenses, SSITWR is not 
for you.  We need to use a more traditional or manual 
reporting system. 
   
   An interesting fact is that for transition age use, people 
who are claiming the student earned income exclusion as long 
as that's the only work incentive, can use the telephone wage 
reporting system in the SSI program.  Many of you will know 
from reading your manual and getting training that the student 
earned income exclusion is the only work incentive that is 
truly automatic.  That if you are eligible for this, it is 
applied automatically.  Doesn't require a request, it doesn't 
require certain forms or documentation.  Social Security is 
supposed to know who is eligible for this, who is under the 
age of 22 and regularly attending school.  And then it just is 
applied before any other work incentives so it's taken right 
off the top. 
   Parents or spouses who are not disabled and have income that 
will be deemed to the beneficiaries, that is also a good 
candidate for using the SSITWR system.  That may not have 
occurred to folks, but it certainly is.
    
   Even a concurrent beneficiary can use the SSITWR system as 
long as SSI is received you can use this assuming you have no 
other special work incentives claimed besides student or 
earned income exclusion.  There is a note at the bottom, 
warning, warning, that concurrent beneficiary is still going 
to have to use manual traditional forms of reporting for the 
Title II side.  Remember, we do recommend double reporting for 
concurrent beneficiaries, just to make sure SSI claims rep 
knows I'm working, they are going to treat the earnings in one 
way, Title II knows I'm working, they are going to treat the 
earnings in a whole different way.
    
   Double reporting, just one of the lovely obligations of 
concurrent beneficiaries.  Who is not a good candidate for 
using this automated system?  If you have impairment related 
work expenses, if you meet the definition of statutory 
blindness, you have BEWEs, you are not a good candidate and 
certainly people who are working under a Plan to Achieve Self-
Support.  If you have any of those bells and whistles, sorry, 
you can't use the automated system.  Let's just fall back on 
that manual, the more traditional forms. 
   
   Here is another thing to remind people.  The new automated 
system is what it says:  Wage reporting.  Wage reporting.  It 
does not accommodate you trying to call up and say, my deemed 
income has changed or my in-kind support maintenance has 
changed or any of these things.  It is only automated to deal 
with earned income.  Specifically, wages.  It is not a slide 
here, but I will show you in a minute, self-employment also 
not a good candidate for using the automated wage reporting 
system.
    
   There are some very unique ways that Social Security deals 
with income derived from self-employment, and the wage 
reporting system does not accommodate that readily at all.  
Beneficiaries who have more than one employer in the same 
month, two part-time jobs or switch over, also not good.  It's 
very good for a very limited type of circumstances, but you 
just can't use it for people that have some unique 
complications.  And having more than one employer within a 
given month is not going to be accommodated by this system. 
   
   Now, remember automated wage reporting is not required.  
People may use it if they want to.  They do not have to.  One 
of the things to remind people is if they do choose to use it, 
that you have to make your report within the first six days of 
the following month. 
   
   Now, in the packet of materials that we gave you for this 
event, you should have an instructions from Social Security 
about using the telephone wage reporting system, and even a, 
these work sheets, that are just wonderful for you to figure 
out what you are going to say on the telephone before you 
actually dial the number.  So you are not stuttering and 
mumbling and let me do my math.  Fill out the forms before you 
dial that number and then you will be assured that the right 
information will get communicated. 
   
   If you miss the automated wage reporting systems time frame 
for reporting, those first six days, no big deal.  You do 
manual traditional forms of wage reporting and you can move 
back to the automated system the following month.  No harm, no 
foul.  That is fine.  They don't expect you to use it every 
single month and there isn't a problem if you use manual one 
month and the automated system in another month. 
   
   Here are things to watch out for because if you have used 
automated phone systems yourself and I would guess almost all 
of you have, you know that because it isn't a real person on 
the other end of the line, you really do have to speak very 
clearly, or it gets muddled.  You have to be able to say your 
name, your first name and your last name.  You need to be able 
to understand requests for information that are spelled out by 
the automated system.  Those are recorded requests. 
   
   You either have to speak or be able to use the lovely 
keypad, touch-tone pad to enter the date of your birth and 
Social Security information. 
   
   Now, we all know working with some beneficiaries, this 
system just isn't going to accommodate their disability.  
That's okay.  It is one choice.  For certain people, it will 
be the best choice.  For other people, use more traditional 
methods. 
   You have to make sure that people who choose to use this 
know to call that phone number between the first and the 6th, 
or it won't work.
    
   The name to be used for authentication is the name that is 
on the most recent Social Security card.  You are going to 
really mess up that system if you are verbalizing names that 
are not on the card or it doesn't match.  It won't be able to 
go through and match the name with the SSN, and that's 
critical or the information doesn't take. 
   
   If the individual is reporting wages for another person, 
that is pretty common.  Most of our folks or many of them have 
a representative payee, and it's the rep payee that is going 
to do the reporting.  They need to have their own name, their 
own Social Security, the date of birth information, because 
Social Security needs to know, who are you calling and you are 
calling for this other person.  We need to be able to track 
who you are if you are not the beneficiary.  And that all has 
to be written down, and be prepared on the little work sheets 
that Social Security provides, that are in your packet, so 
that when you dial the number, all that information has been 
written down and you are ready to go.  You are not fumbling 
around trying to find your Social Security card or anything 
like that.
    
   Make sure the report is appropriate for use in this system.  
Not everyone is a good candidate.  Make sure you figure out 
what gross wages are, gross, not net.  Okay?  In the month, 
and I'm going to give you a caution here because you know some 
people do have automatic deposit of their paychecks.  That is 
not going to be gross income that is deposited.  That is going 
to be net.
    
   If you have that automatic deposit, there needs to be a way 
for the beneficiary to go and see the printout, what did I 
actually earn?  How much did they take out in taxes?  A lot of 
times, that will either be mailed to the person, or it may be 
an on-line system, where you actually have to have a code, go 
into a Website, to print out or to look at what, the breakdown 
of your checks, how much was paid in taxes.  Make sure the 
Social Security numbers are handy.  Here is the 800 number to 
call.  Probably should have figured out a way to make this 
flash or something on the screen.  See that that is not the 
main toll-free number for Social Security.  Make sure that 
your beneficiaries do have the right numbers. 
   
   I do have a warning about wage reporting for self-
employment.  It is different.  For both Title II and SSI, it's 
net earnings, self-employment that has to be counted.  Not 
gross income.  And certainly not the infamous owner's draw, 
which there is more material on our Website and in your manual 
explaining the difference between gross receipts, net earnings 
from self-employment and owner's draw.  It is net earnings 
from self-employment that Social Security cares about.  What 
is that?  It's, you develop NESE by you taking the gross 
profits, and profits means what did you bill, minus what is 
allowable business expenses did you incur, and then you 
multiply that profit by a figure of  .9325.  That is an 
important figure there.  Actually I think it might be .9235.  
That might be a typo on the screen.  Sorry about that.  
Countable NESE might be further reduced by work incentives.  
What does that mean?  A lot of reporting responsibility and 
let's not use the automated telephone wage reporting system.  
Self-employed people you would never use that system. 
   
   The biggest problem people cause for themselves is not 
keeping their books on a regular basis, so they don't know 
what their profit is, they don't know what the net earnings 
from self-employment is.  And keeping those good business 
accounts is absolutely critical.  Another problem we see is 
actually being too diligent in the wage reporting.  That can 
cause more problems than actually not reporting at all, 
believe it or not, because in many cases they are looking at 
your annual profit, what you are showing at the end of a tax 
year, you don't know what that is until the year ends.  You 
might have a loss one month, and a profit one month. 
   
   If you are reporting monthly, you are going to create havoc 
for yourself and for that claims rep.  Typically, we need to 
wait until the end of that tax year, when all the taxes are 
prepared, and you report an annualized basis. 
   
   There are some tips that we have offered you here.  For any 
of you that have taken the training that we are running this 
spring on self-employment, these are reiterated from those 
slides.  When your Title II beneficiary, you should keep your 
business, financials on a monthly basis, at first, so you are 
clear when TWP months have been used and when TWP has ended.  
You report each month in which net earnings is over the 
current TWP amount, or remember in the Title II program, if 
you work a certain number of hours, even if you incurred a 
loss, that can be a trial work period month.  Typically, 
sending in month by month profit and loss statements will work 
for this.  You don't have some special form.  You have a month 
by month profit and loss statement. 
   
   Tip number 2, after the trial work period ends, at that 
point in order for Social Security to figure out if you are 
engaging in SGA, they need aggregate data.  They need you to 
show that year of profit and loss.  So you won't want to look 
at individual months, because remember, you can lose money, 
you can have a profit, you want to use that annual tax return, 
and that is what they are going to use to determine whether or 
not you are engaging in your SGA so people need to get their 
taxes done on time and get them submitted to Social Security, 
so that check can either be ceased or continued as the case 
may be. 
   
   Finally, never report gross income to Social Security when 
you are self-employed.  Gross income is I have billed all my 
customers this amount.  Well, if you report that, they are 
going to use that.  But that isn't what is, Social Security is 
supposed to use.  That is not going to take into account all 
the expenses you incurred.  It is not going to take into 
account that net earnings for self-employment, and you need to 
be careful that the information submitted is correct. 
   
   Now, in the SSI program, you know it has to be different.  
NESE is determined at the end of the first year of operations.  
You really can't see what is going on in the SSI program by 
reporting monthly.  This is a situation you really have to 
tell Social Security, I'm engaged in self-employment, but I 
don't know what I'm earning.  You wait for the end of the 
first calendar year.  You report your total profits then.  
Then Social Security actually retroactively adjusts your cash 
payments based on the profit or the loss that you incurred for 
that full year, and they retroactively go and determine, we 
should have paid you this, we did pay you this, we owe you, 
you owe us.  It's the settling up that you are familiar with 
through redetermination.
    
   Okay, some tips.  If you are not expected to make a profit, 
and that you don't, you can certainly send in your tax 
returns, but nothing is going to happen there.  If you do make 
a profit, make sure you get those tax returns in, so that 
Social Security can retroactively adjust those payments.  
After that initial year of operations, you need to watch out 
for what you are projecting for NESE.  In the SSI program they 
are going to take your first year, they are going to look at 
whatever profit you have, and unless you tell them otherwise, 
they are going to use that as an estimate to adjust your check 
prospectively, and so if your estimate is poor, you end up 
making way more money or way less money, you are going to end 
up either getting overpaid or underpaid.  One of those things 
you have to stay on top of.  It's the way the system works. 
   
   You need to be reporting as the estimate fails to match up 
with what are the actuals.  Finally, the beneficiary, you just 
really, what I just said, you have to diligently and carefully 
track your actual net earnings from self-employment, make sure 
that that data is submitted to Social Security, make sure you 
keep a copy of everything, so that that check can be adjusted 
correctly. 
   
   Remember, general reminders, many of these are things you 
may already know.  When you report work incentives, you have 
to keep the receipts.  BEWEs, IRWEs, you know what those are.  
Your past expenses, you have to have receipts.  If you lose 
your receipts and we have all dealt with this, there are a 
couple of other options, you can ask doctors or pharmacies for 
printouts.  Sometimes you can even use credit card statements 
or canceled checks.  The best way is to keep receipts.  But 
there are a few instances where there is a fallback position 
that you can sort of use in a pinch. 
   
   If you are reporting by mail or Fax, remember use pay slips, 
keep receipts.  You need to submit them with a letter, that is 
where you need to use that notice of change in earnings status 
or whatever your agency has developed.  There should be 
something in writing.  Don't just mail in receipts.  You have 
to attach that to a letter so the claims rep knows who it is, 
and how to apply this.  Finally, I want to reiterate to you, 
what a tremendous payoff there is in you spending the time to 
teach individuals to fish, okay, to report.  How important 
that is, getting that habit of keeping the pay stubs, making 
sure the receipts for those IRWEs and BEWEs are retained.  If 
you can check on the person periodically, are you doing this, 
this is what you told me you were going to do, and then 
teaching beneficiaries to know when you report, this is what 
should happen to your check.
    
   And if the check isn't doing what you think it should, that 
doesn't mean all is well.  That may mean, we have a problem.  
So we have to prepare beneficiaries to expect problems, they 
occur, and then what to do to fix them.  And teaching 
community partners, let me tell you how important that is. 
   
   That job coach, that case manager, that therapist at the 
mental health center, these are folks that have a lot of 
contact with beneficiaries, if we can teach them how to do 
this, we can avoid so many problems.  And the 
misunderstandings people have about reporting, you know that 
they are just outrageous.  So it's a lot of myth busting that 
we need to do and teaching constantly, and supporting and 
answering questions, and following up, monitoring, monitor, 
monitor, monitor.  Make sure it's being done.  Make sure the 
check really is being adjusted, or the trial work period 
months are being recorded, all of that to ensure that the 
individual won't be overpaid or underpaid.  And then by 
George, you better be available to do the sweep-up, because no 
matter how diligent we are, no matter how competently we 
report things, it's a huge system.  And things get dropped.  
Things get done wrong.  We need to be sweeping up behind that 
beneficiary, just to make sure that everything is being done 
appropriately. 
   
   So, for many of you, this was a review.  For some of you, 
this might have been new information.  But I'm glad that you 
pulled us up on the computer and spent an hour or so of your 
time.  And don't forget, the chat room is available 
immediately following this, and if you have questions, I'd be 
delighted to answer them.  Thanks for joining us. 
   
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