November 15, 2001

Mr. Larry G. Massanari
Acting Commissioner
Social Security Administration
6401 Security Boulevard
Altmeyer Building, Room 900
Baltimore, MD 21235

Dear Mr. Massanari:

     On August 21, 2001, the Social Security Administration (SSA) submitted a final regulation entitled "Rules Implementing the Ticket to Work and Self-Sufficiency Program." The program provides disabled beneficiaries with expanded options for access to employment services, vocational rehabilitation services, and other support services. Under the provisions of this rule, SSA will pay the providers of these services after beneficiaries achieve certain levels of work. In conducting its review of the rule, OMB has raised questions regarding the payment system established in the rule, its administrative complexity, and readability. We believe that a number of issues require additional clarification, including:

• How the milestone and outcome payment systems will work in practice
• How various provisions of the regulation apply to State Vocational Rehabilitation Agencies
• The responsibilities of Employment Networks participating in the Ticket to Work Program
• The timing and complexity of Ticket to Work reporting requirements for Employment Networks and State Vocational Rehabilitation Agencies.

     We look forward to receiving SSA's response to the questions originally raised in our October 5, 2001 e-mail memo so that we can work together to resolve these complex issues. Since the revisions necessary to address these concerns are likely to take a substantial amount of time, I am returning this rule to the agency for your reconsideration. My staff is available for further discussion. We look forward to working with you to improve these important rulemaking efforts.