SSA - POMS: DI 60075.035 - Promoting Opportunity Demonstration (POD) Participation Period

A. POD participation period

A POD participant can be eligible for the $1 for $2 offset for a maximum of 43 months, depending on the date of enrollment. A beneficiary is eligible for only one participation period.

1. POD participation start date

The POD participation start date is the date of random assignment. Eligibility for the $1 for $2 benefit offset begins the first month after random assignment. The earliest start date for a POD beneficiary is December 1, 2017. The latest start date is December 31, 2018.

2. POD participation end date

All participants assigned to a treatment group will have a participation end date of June 30, 2021. Participation can end prior to June 30, 2021 if the beneficiary dies, reaches full retirement age (FRA), or requests a withdrawal from the POD.

NOTE: The participation period Start and Stop dates are on the DEMO screen in the Disability Control File (DCF).

B. Disability entitlement terminated prior to random assignment

A potential POD participant whose disability benefits terminate prior to assignment to a POD treatment group is not eligible for POD. This includes retroactive terminations.

C. Disability entitlement terminated during the participation period

Participants assigned to treatment group 2 are the only POD participants subject to a POD rules work termination. (For information on the POD work terminations, see DI 60075.010A.2.) However, all participants are susceptible to medical cessation.

1. Treatment group 2 termination due to 12 consecutive months of complete offset

If a participant in treatment group 2 has 12 consecutive months of full offset, entitlement to Social Security Disability Insurance (SSDI) terminates effective the last day of the 12^th month of full offset. POD participation will continue despite the fact that the participant is not entitled to benefits. If the participant has entitlement reinstated, the participant will again be eligible for the $1 for $2 offset.

2. Termination for reasons other than 12 consecutive months of complete offset

If a POD participant’s entitlement to disability benefits terminates for reasons other than 12 consecutive months of complete offset after the month of random assignment, the beneficiary’s participation period continues despite the fact that the participant is not entitled to benefits. If the participant has entitlement reinstated, the participant will return to the same treatment group the participant was in before termination and will again be eligible for the $1 for $2 offset.

D. Extended period of Medicare coverage (EPMC)

A POD participant in treatment group 2 who has their SSDI benefit reduced to zero for 12 consecutive months will have their SSDI entitlement terminated. If the participant is entitled to Medicare and has entitlement terminated due to 12 consecutive months of zero benefit, the POD will provide 93 months of EPMC from the month of termination as long as the participant continues to have the same disabling impairment(s) that provided the basis for the prior SSDI entitlement and meets the other SSDI entitlement requirements. The automatic 93 months of EPMC applies only to participants who terminate due to POD offset rules.

To calculate the Medicare end date for a beneficiary that completes POD participation and terminates under regular SSDI SGA rules, follow these steps:

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determine the POD start date;
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determine the date of the last work CDR decision prior to the POD start date;
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determine the POD end date;
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use steps outlined in HI 00820.025A.4 to determine the Medicare end date; and
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exclude all months from the date of the last work CDR decision to the POD end date in the EPMC calculation.

Example:

DIB LINE information provided for termination:

DDO-05/11/2010 DIG-3890 DIB DOED-11/2010 MEDICARE DOED-11/2010 ADC-04/16 CDR-E DBC-10/2021 EBD-04/16

According to the HISTDEMO on the Master Beneficiary Record (MBR), John Doe participated in the POD from 01/2018 to 06/2021. The last work CDR decision prior to the start of their POD participation was 05/10/2017. In 10/2023, a post-POD work CDR was completed and it determined that their benefits terminate 08/2023 due to SGA.

According to the DIB LINE on the MBR, John Doe's extended period of eligibility (EPE) begin date (EBD) is 04/2016. Their cessation date (ADC) is also 04/2016, which is prior to the 14^th month of the EPE. To determine their Medicare end date, we must determine if they worked in the 16^th month of the EPE.

Since the POD does not evaluate the period from John Doe’s pre-POD work CDR to the end of POD participation under regular SGA rules, the period from 06/2017 to 06/2021 does not apply when calculating the Medicare end date.

To determine the 16^th month of the EPE, count from the first month of the EPE through the month of the last work CDR decision prior to POD. That is 04/2016 to 05/2017, which is 14 months. Then, exclude the period starting 06/2017 through 06/2021. Begin counting the EPE again starting the month after POD participation ends. The 16^th month of the EPE is 08/2021.

Use HI 00820.025A.4 to determine the Medicare end date. If John Doe worked above SGA in the 16^th month of the EPE (08/2021), their Medicare ends the last day of the 57^th month (01/2028) following the end of the 36-month EPE (04/2023). If they did not work above SGA in the 16^th month of their EPE (08/2021), Medicare ends the last day of the 77^th month following the first month SGA occurs.

E. Disability re-entitlement during the participation period

If the beneficiary becomes re-entitled based on a new application for disability benefits or expedited reinstatement (EXR), eligibility for the $1 for $2 offset begins with the new month of entitlement. During POD participation, the trial work period (TWP) and initial reinstatement period (IRP) that would normally apply after reinstatement will not apply.

F. Termination of POD participation period prior to the end date of the demonstration (06/30/2021)

The POD will end for all treatment group participants on June 30, 2021 unless one of the following events occur:

1. Participant dies

If a POD participant dies while participating in the POD, we will consider the POD participation period to have terminated the month before the month the participant dies.

2. Participant attains full retirement insurance benefits (RIB)

If a POD participant attains RIB, even though entitlement to disability insurance benefits (DIB) technically continues (i.e., DIB to RIB or Disabled Widow(er)’s Benefits (DWB) to Widow(er)’s insurance benefits (WIB)), we will consider the POD participation period to have terminated the month before the month the participant attains RIB.

NOTE: It is possible for a beneficiary to be simultaneously entitled to a benefit based on disability and a benefit not based on disability (e.g., HA/DWB) and full retirement is attained on one of these entitlements, but not the other. If this occurs after POD enrollment, the POD participation period terminates for the non-disability based entitlement (retirement or survivor benefit) but continues for the disability entitlement.

3. Participant withdraws

If a POD participants elects to withdraw from the POD, we will consider the POD participation period to have terminated the last day of the month of the withdraw request.

G. POD participation period ends

As of the first month after POD participation ends, a participant will again be subject to regular SSDI rules. The TWP, EPE, and IRP are frozen during the POD participation period. The TWP, EPE, or IRP will continue the month after POD participation ends and begin at the same point the beneficiary left off when participation began. If a beneficiary’s entitlement terminated during the POD and they refiled an initial claim or EXR, they will begin a new TWP or IRP the month after POD participation ends.

1. Trial work period (TWP) not complete

If a POD participant has not completed the TWP prior to the POD start date, they will return to the next month in sequence beginning the month after POD participation ends. The months of earnings during POD participation period do not count as TWP months, but the months of POD participation do count as part of the rolling 60-month period.

Example: A beneficiary volunteers and is randomly assigned to the POD on January 15, 2018, marking the start of the POD participation period. The last work CDR completed before that date determined that the beneficiary had completed four TWP months. The beneficiary exits the POD on June 30, 2021. The beneficiary is eligible for TWP month number five beginning the first month after POD participation ends. If any of the four TWP months recorded prior to POD participation in January 2018 are more than 60 months prior, the beneficiary’s TWP will adjust accordingly.

2. Extended period of eligibility (EPE)

A POD participant who enrolls in the POD while in the EPE will have the EPE frozen during the POD participation period. The beneficiary will begin with the next EPE month in sequence upon exiting the POD participation period.

Example: A beneficiary volunteers and is randomly assigned to the POD on January 15, 2018, marking the start of the POD participation period. The last work CDR completed before that date determined that the beneficiary completed 20 EPE months. The beneficiary exits the POD on June 30, 2021. The beneficiary will enter regular SGA-evaluation rules beginning the month after POD participation ends and will resume in month 21 of the EPE.

3. EXR initial reinstatement period (IRP)

A POD participant who enrolls in the POD while in the IRP will have the IRP frozen during the POD participation period. The beneficiary will begin with the next IRP month in sequence upon exiting the POD participation period.

Example: A beneficiary volunteers and is randomly assigned to the POD on January 15, 2018, marking the start of the POD participation period. The last work CDR completed before that date determined that the beneficiary completed 10 IRP months. The beneficiary exits the POD on June 30, 2021. The beneficiary will enter regular SGA-evaluation rules beginning the month after POD participation ends and will resume in month 11 of the IRP.

NOTE: The presence of SGA determines the completion of IRP months, so if a beneficiary exits the POD and is engaging in SGA during their IRP, they will not get credit for another IRP month until work has dropped below the SGA threshold.

Social Security

Program Operations Manual System (POMS)

DI 60075.035 Promoting Opportunity Demonstration (POD) Participation Period