Document the file as to whether the fee (or some portion of it) for preparing a PASS
is reasonable. In assessing the reasonableness of the fee, consider the overall involvement
the preparer had in the development of the PASS, such as aptitude testing, counseling,
and any other pertinent services.
If the preparer has filed an SSA-1696-U4 to serve as the individual's appointed representative,
be sure that no part of the preparation fee is for services performed as the representative.
Payments to a representative involve a specific SSA billing process, see GN 03920.001.
If a PASS must be modified, do not approve charges for preparing the modification.
Do not allow fees for monitoring the person's progress towards an approved work goal.
EXAMPLE: A PASS includes a $1,000 expense for a local private VR agency's assistance with
the PASS. You contact the agency to determine whether the expense is reasonable.
You learn that the agency has been certified by the state, worked closely with the
individual in developing the PASS, and assessed the individual's interests and abilities
to help identify an appropriate work goal. The agency also plans to monitor the PASS
to ensure that the individual complies with all requirements.
The agency estimates that a counselor spent 12 hours assessing the individual's vocational
abilities and an additional 8 hours developing the PASS. It values this assistance
at $35 per hour, for a total of $700. The rest of the fee is for the planned monitoring
You determine that $420 (12 hours at $35 per hour) is reasonable for a vocational
assessment by a state-certified private VR agency. You also determine that $280 (8
hours at $35 per hour) is a reasonable fee for preparing the PASS itself. However,
you inform the VR agency and the individual that fees for monitoring a PASS are not
allowable expenses, and the PASS must be modified to remove the $300 portion of the
overall fee that is for monitoring.