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

A. POD participation period

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

Now that the POD has ended, the POD participation period is now closed for all participants. Offset may no longer be adjusted in the participation period and offset may not be applied to benefits outside of the participation period.

1. POD participation start date

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

2. POD participation end date

All participants assigned to a treatment group have a participation end date of June 30, 2021. Participation could end prior to June 30, 2021 if the beneficiary died, attained full retirement age (FRA), or requested 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 was not eligible for POD. This included retroactive terminations.

C. Disability entitlement terminated during the participation period

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

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

If a participant in treatment group 2 had 12 consecutive months of full offset, entitlement to Social Security Disability Insurance (SSDI) terminated effective the last day of the 12^th month of full offset. POD participation continued despite the fact that the participant was not entitled to benefits. If the participant had entitlement reinstated, the participant was 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 terminated for reasons other than 12 consecutive months of complete offset after the month of random assignment, the beneficiary’s participation period continued despite the fact that the participant was not entitled to benefits. If the participant had entitlement reinstated, the participant will returned to the same treatment group the participant was in before termination and was 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 had their SSDI entitlement terminated. If the participant was entitled to Medicare and had entitlement terminated due to 12 consecutive months of zero benefit, the POD provided 93 months of EPMC from the month of termination as long as the participant continued to have the same disabling impairment(s) that provided the basis for the prior SSDI entitlement and met the other SSDI entitlement requirements. The automatic 93 months of EPMC applied only to participants who terminated due to POD offset rules.

To calculate the Medicare end date for a beneficiary that completed POD participation and terminated 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), a beneficiary 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, the beneficiary'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 the beneficiary'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 the beneficiary 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 became re-entitled based on a new application for disability benefits or expedited reinstatement (EXR), eligibility for the $1 for $2 offset began 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 do not apply.

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

The POD ended for all treatment group participants on June 30, 2021 unless one of the following events occured:

1. Participant died

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

2. Participant attains full retirement insurance benefits (RIB)

If a POD participant attained RIB, even though entitlement to disability insurance benefits (DIB) technically continued (i.e., DIB to RIB or Disabled Widow(er)’s Benefits (DWB) to Widow(er)’s insurance benefits (WIB)), we considered the POD participation period to have terminated the last day of 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 occurred after POD enrollment, the POD participation period terminated for the non-disability based entitlement (retirement or survivor benefit) but continued for the disability entitlement.

3. Participant withdraws

If a POD participants elected to withdraw from the POD, the POD participation period 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 is subject to regular SSDI rules. The TWP, EPE, and IRP are frozen during the POD participation period. The TWP, EPE, or IRP continues the month after POD participation ends and begins 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 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 returns 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 had the EPE frozen during the POD participation period. The beneficiary begins 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 enrolled in the POD while in the IRP had the IRP frozen during the POD participation period. The beneficiary begins 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 exited the POD and was 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