Phase 1 Milestone Exclusions

There are factors that can result in an EN being excluded from receiving Phase 1 Milestone payments even when a beneficiary achieves qualifying earnings. Those exclusions are:

  • Prior VR Services Rule: All Phase 1 milestones are excluded from payment if a beneficiary received services from a State Vocational Rehabilitation (VR) agency and the most recent case was a successful closure (meaning the beneficiary had worked at least 90 days at case closure). This rule applies to all successful closures since January 2002. The assumption here is that the State VR agency provided the services leading to job placement and short-term stabilization in employment. Social Security is not authorized to compensate two organizations for providing these up-front services.
  • 18-Month Lookback Rule: If a beneficiary had Trial Work Level (TWL) earnings during some or all of the 18 months prior to the first Ticket assignment, some or all of the Phase 1 Milestones may be excluded from payment. Access the 18-Month Lookback Tool in the Information Center on the Resource Documents page. The earnings criteria used for payment of Phase 1 Milestones are reversed to determine eligibility for payment based on the 18-month lookback rule as noted below.
  • P1M1 is not available if a beneficiary worked with earnings above the TWL in the calendar month immediately prior to Ticket assignment.
  • P1M2 is not available if a beneficiary worked with earnings above the TWL in 3 of the 6 months immediately prior to Ticket assignment.
  • P1M3 is not available if a beneficiary worked with earnings above the TWL in 6 of the 12 months immediately prior to Ticket assignment.
  • P1M4 is not available if a beneficiary worked with earnings above the TWL in 9 of 18 months immediately prior to Ticket assignment.