Some State DDS agencies receive requests from various other agencies within the State to make disability determinations for claims not related to SSA benefits, claims commonly known as “Non-SSA Program” claims and primarily involving various categories of nonpayment Medicaid-only cases. Most of these requests come from State welfare agencies, particularly in States where the DDS is contained within a parent or “umbrella” agency of the State welfare department. In a few States, the DDS has been asked to make disability determinations by other agencies, such as those administering teachers' retirement systems, State employees' retirement systems, and State homestead acts.

The DDS's must ensure that the non-SSA program work does not hamper the ability of the DDS to fulfill its obligations under SSA regulations. Where such work is assigned to the DDS, it is to be predicated upon

(1) the recognition and payment of all costs by the State, direct and indirect, in accordance with State and Federal laws;

(2) assurance to the regional commissioner that no delay in SSA claims will result; and

(3) assurance to the regional commissioner that the funding and reporting system is consistent with the guidelines outlined in this section.

Experience has indicated that the workload for non-SSA program work has been such that in only a few cases is it large enough to warrant a completely separate unit for its administration. In those cases, although the DDS has been called upon to set up the unit and furnish a staffing cadre, the funding, and staffing are the responsibility of the “other” state agency, presenting no problem to the DDS administration.

In most cases, however, the workload does not warrant setting up a separate, independent work group. Instead, the staffing and other resources must be shared and allocated between the SSA program work and the non-SSA program work. This requires that all the costs of the non-SSA program work be clearly identified to provide accurate cost allocations.

The Social Security Act and the regulations providing for the administration of the disability programs permit appropriate funds to be used only for the purposes specified in titles II and XVI of the Act.

1. 1. 

   Separate Unit Funding

   This legal requirement poses no problem in the financial relationship between the independent unit and the DDS since the funding of the independent unit is completely outside the DDS budget.

2. 2. 

   Concurrent Funding of a Single Unit

   The funding and staffing of the joint operation, however, does present some difficulties. A split operation ordinarily brings with it inherent problems in estimating costs; apportioning costs; and maintaining accurate, reliable records for data accumulation, monitoring, and management purposes. Moreover, the addition of a concurrent payment system compounds the complexities of the financial management system. In some States, obtaining funding authority and drawing appropriated funds are processes sometimes protracted even beyond the limits permitted by operating needs.

3. 3. 

   The Cash Flow System

   Nevertheless, in the joint operation, the regulatory constraints make it necessary for the State to draw concurrently upon the resources provided by both the Federal government and the State government for the payment of the costs shared in doing the SSA work and the non-SSA program work. Reimbursement after the fact would constitute use of appropriated funds, albeit temporary, for purposes not authorized by the Social Security Act or the Federal-State regulations. A satisfactory cash flow system then, is one which provides a fund of working capital and establishes a system for paying the costs of doing the work as the costs are incurred. Thus, the State will need to (1) merge the funds appropriated for this work with those of the DDS and (2) integrate procedures to provide for payment of shared costs.

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