1. Introducing PASS
2. How a PASS Works
3. The Impact of PASS
4. PASS Candidates
5. Students & Transition Planning & PASS
6. When First Considering a PASS
7. The Occupational Goal
8. Starting a Business
9. A Viable Plan
10. Stumbling Block
11. The PASS Life
The PASS must outline the steps or milestones and corresponding time-frames leading to attainment of the occupational goal. These milestones help to demonstrate the person's progress toward achieving the goal and should be described sufficiently so that completion of steps are easily recognizable. Milestones are best-documented using specific language.
For example, "attend and complete fall 2023 semester at college". Additionally, the milestones and correlating time frames should include planned PASS expenditures. The milestones should be listed in the progression as they are expected to occur. The last milestone listed on the PASS application should always indicate the obtainment of the occupational goal.
Specific time frames must be established for each milestone listed. These time frames should indicate the month and year in which each milestone is expected to begin and then completed. The time allotted must be reasonable in its relation to the goal and reflect the person's estimated time for completing the goal based on their own particular situation.
The PASS must identify the income and/or resources that are being used to fund the PASS such as SSDI benefits, countable wages or an inheritance. The income or resources must be sufficient to meet the outlined PASS expenses. These funds must be adequate, but not excessive, in reaching the occupational goal. The PASS must also show how income/resources set aside will be kept clearly and easily identifiable. Separate bank accounts for PASS savings are a good way to provide for verification of PASS savings and expenditures.
The PASS is meant to provide for "seed money". It should not be expected that PASS will pay for more than what a person needs in order to successfully begin and maintain employment. The PASS must state how the money set aside will be spent to achieve the occupational goal. A list of proposed expenditures should be included with the PASS application. Expenses necessary for achieving the goal must be reasonable in price to be approved. Cost estimates for goods and services indicating how the costs were calculated should be included along with the sources for pricing. Goods and services under the PASS may be bought outright, rented or leased. In the case that an item of unusual value is to be purchased, the PASS must include a satisfactory justification as to why less expensive alternatives will not suffice. Some examples of items that may qualify as PASS expenditures include:
No expenditures will be approved if:
If there are questions about whether items or services are appropriate for inclusion under a PASS, please ask your benefits specialist or SSA's PASS specialist. Take note that individuals who are denied a proposed PASS are entitled to the reason(s) in writing from the local SSA office. If you do receive a denial, you can contact one of the agencies listed later for further advice and information.
Not all expenses may be allowed at the beginning of the PASS. In some cases, approval of certain goods and services may be contingent on the successful completion of milestones before further expenses will be approved.
Individuals in a supported employment situation may also use a PASS to increase potential for self-support. An individual's goal can be to achieve stabilization or to reach an even higher level of independent performance as described in the PASS. This will generally occur through decreasing their costs for, and their reliance upon ongoing supports needed to work. A knowledgeable source, such as vocational rehabilitation counselor or employer, may be contacted to help to determine the types, amount and duration of supports necessary for increased independence. While extended or follow-along services generally would not be allowable under a PASS, they may be allowed if increased earnings reflect a decrease in the amount of SSI entitlement.
PASS Expense or Impairment Related Work Expenses (IRWE)Many items or services that are allowable under a PASS may also meet criteria for exclusion as an IRWE. (Put in link) However, you cannot claim the same expense for both.
When items or services meet criteria for both PASS and IRWE, it is better to establish a PASS because of the order in which these two exclusions are applied in the SSI benefit computation. An example of a vocational goal-related service calculated as an IRWE first and then as a PASS may best demonstrate the differences between the two work incentives. Two examples follow:
John must purchase job coaching services to assist in initial job training. The expense is $100 per month. This expense meets criteria for exclusion under both IRWE and PASS. John receives $456.50 a month in SSI and earns $500 in gross wages. His current monthly income is $956.50 from these sources. Once the expense is paid for over and above his SSI check, John's spendable income is $889.50.
The difference in the methods of calculating IRWE and PASS results in a 100% reimbursement of job coaching expense under PASS, and only a 50% reimbursement of the same expense under IRWE. As illustrated, it would be better for John to establish a PASS to pay for this expense.
Some items established as a PASS may be switched to IRWE when the PASS exclusion is no longer available. Remember that it is usually better to use the PASS work incentive instead of the IRWE. Both options should be investigated with the assistance of the local SSA office to determine the best option for each situation. It is permissible to have a PASS for one or more expenses and at the same time have an IRWE for other work-related expenses not covered by the PASS.