Important SSA Information on Impairment Related Work Expenses (IRWEs) and Work Incentive Planning and Assistance (WIPA)
Do you collect SSI or SSDI benefits? If so, the below information is very important.
Impairment Related Work Expenses (IRWEs)
As of January 2018, if you are receiving SSDI benefits and your earnings exceed the Substantial Gainful Activity (SGA) limit set at $1180 per month for individuals with disabilities other than blindness and $1970 for individuals with blindness, you could lose your SSDI check for that month. The exception is if you are still in your trial work period. While most of you are familiar with the nine (9) month trial work period, the SSA has another mechanism in place which allows you to exceed the $1180 (or $1970 earnings) limit for a given month, yet remain entitled to your SSDI check. That mechanism is to subtract the cost of Impairment Related Work Expenses, or IRWE's from your earnings before the SSA "counts" your wages to determine if you have exceeded the SGA for a given month.
What are examples of IRWEs?
Consider the cost of heating and/or air-conditioning your home work space, high speed Internet costs, second phone lines, unlimited calling plans, computer maintenance, some repairs and office supplies. Many of you are incurring unreimbursed home office related costs of $80-$150 per month.
Here is an example: You have spent $120 per month on unreimbursed home-office expenses, which can be deducted from your total earnings for the month as eligible IRWE's. A person with a disability other than blindness could earn $1300 per month of wages and an individual with blindness could earn $2090 without jeopardizing your SSDI checks. Did you know IRWE's also matter to those of you receiving SSI benefits? The cost of IRWE's should be deducted from your monthly wages to come up with "countable wages". The size of your monthly SSI check varies with your countable wages for that month.
NTI is aware your SSI and/or SSDI check(s) are critical to you; NTI does not want you to endanger your benefits. We also know, in several states, employees encounter difficulties trying to use the IRWE information within their local SSA field offices. NTI has obtained an important update and is pleased to have been part of initiating a clarification that will be of help to you. This formal notification NTI has received from the SSA confirms unreimbursed home office expenses are considered eligible IRWE's for employees of the NTI telework program. (Note: If you work on a contract where you receive a telecommunications expense reimbursement (TERF) each month, the amount of the expenses you were reimbursed for ARE NOT deductible as an IRWE.)
You may also have other expenses each month, such as medications and co-pays, which are eligible expenses to deduct.
The below language has been relayed to NTI on April 2nd, 2010, by Mary Hoover, the Employment Policy Team Leader and individual responsible for the policy on IRWE's. The update to the SSA's Program Operations Manual System (POMS) should be standard operating procedure for field office employees throughout the country. However, those field office employees who rarely, if ever, see these cases may not be familiar with the procedures. Employees when contacting their local field offices to claim IRWE's should be instructed to cite the POMS reference DI 10520.010G.3 (under Definition of Residential Modifications).
3. Tele-Work Modifications
An employer may establish a special tele-work program to accommodate the needs of employees with disabilities who need home-based work. The costs for the purchase and maintenance of equipment necessary for tele-work are deductible as IRWE when the individual works under such an employer tele-work program which was designed exclusively for one or more employees with disabilities. Examples of items in this category which may be deducted as IRWE include high speed internet service, a second phone line, and computer maintenance. This excludes optional tele-work, temporary off site work, work at home after regular hours, or while traveling.
Click on this link and scroll down to Section G, # 3.
How do I actually claim my IRWE's?
The information above and on the SSA website, plus your saved receipts for any eligible expenses and iPay earnings statements for each pay period, should essentially ensure that you will pass an "audit" by your local SSA office. NTI highly suggests you contact your local SSA representative/benefits planner by phone, email or in person and:
1) Request verification (if you have not already done so and received verification) of what IRWE's you have.
2) Check to see if you have any trial work period months available to you (SSDI recipients)
3) Give to the SSA representative/benefits planner the reference information above, and explain that you are an employee of the NTI telework program and you typically incur monthly home office expenses of $____________.
4) Ask the local SSA representative to respond to your email or send you a written response verifying that they are in agreement that you can subtract the cost of home-office IRWE's from your countable wages for SGA purposes. **You will want to tell the SSA representative to refer to the following programmatic instruction which is applicable to NTI employees: DI 10520.010G.3.
If your local Social Security office does not understand the programmatic instructions, the SSA office has the ability to clarify the policy. Every office has a work incentive liaison and Areas have work incentives coordinators who can serve as resources. In addition, every regional office has policy staff familiar with work incentives. If the regional staff is unable to resolve your question, the staff in the Office of Program Development and Research should be contacted.
Will the SSA office question my earnings?
Yes, an inquiry could be made by a representative of your local SSA office. An email or letter from your local SSA office representative about your specific situation, your home office expense receipts, your iPay earnings statements for each pay period, and the SSA programmatic instruction information above is your triple assurance that you will be found to be in compliance with the SSA rules and regulations.
What do IRWE's have to do with the hours I work?
There are at least two months each calendar year with three pay periods instead of two pay periods. It is expected you will work your scheduled hours and shifts required for your position. Additionally, on occasion, your employer may also ask you to work extra hours in a busy month. Sometimes employees become worrisome about their monthly earnings or "going over." This is why it is extremely important to know what IRWE's you have and/or if you have any trial work period months available to you.
We urge you to contact your local SSA representative/benefits planner now so you can clarify and have confirmation of your own particular situation regarding IRWE's and trial work period months. If you have spoken with an SSA representative/benefits planner in the past but were told these expenses were not IRWE's for NTI employees, contact your local SSA office again with the SSA programmatic instruction number above.
In the event that you would like to read more about IRWE's, please refer to the SSA Red Book.
Work Incentive Planning and Assistance (WIPA)
Are there any other services that can help me?
Yes! If you are not satisfied with the information you received from your local SSA office regarding your SSA benefits and/or IRWE's, every state has several assistive organizations called Work Incentive Planning and Assistance Projects (WIPAs). These organizations receive grants from the SSA to assist SSA beneficiaries with benefits planning, job placement, career development, including work incentives like IRWE's. This is a free service to all SSA beneficiaries.
What can I expect from a WIPA office?
WIPA can help you to make informed choices about work. Ask to speak with a Community Work Incentive Coordinator (CWICs) to:
- provide work incentives planning and assistance;
- help beneficiaries and their families determine eligibility for Federal or State work incentives programs;
- refer beneficiaries with disabilities to appropriate Employment Networks or State VR agencies based on individual needs and impairment types;
- provide general information about potential employer-based or federally subsidized health benefits coverage available to beneficiaries once they enter the workforce; and
- inform beneficiaries with disabilities of further protection and advocacy services available to them
WIPAs are authorized to serve all SSA beneficiaries with disabilities, including transition-to-work aged youth, providing benefits planning and assistance services on request and as resources permit. To locate you state or local WIPA office, please follow this link.