# LINTEL ## A National Framework for Moving People Off Disability Benefits Into Ownership **Fourth in the reformation series.** Companion to CORNERSTONE (prison), the drug reformation model, and STANDFAST (veterans). Born Between 2 Generals, LLC · Data year 2026 --- ## Part I — What This Framework Is Actually Fixing ### The premise that has to be corrected first The common belief is that people collect disability benefits for addiction, and that closing this loophole is the reform. The loophole was closed thirty years ago. Public Law 104-121, signed March 29, 1996, barred payment of Disability Insurance and Supplemental Security Income where drug addiction or alcoholism is material to the finding of disability. SSA sent termination notices to more than 209,000 beneficiaries in June and July of that year — about 2.6% of DI worker and SSI disabled-adult beneficiaries at the time. Fifty-seven percent were SSI-only, twenty-two percent were concurrent, twenty-one percent were DI-only. What remains is the **materiality determination**, now governed by SSR 13-2p, effective March 22, 2013. SSA runs the five-step sequential evaluation twice and asks one question: would this person still be disabled if they stopped using? If a separate condition would remain disabling on its own, benefits are payable. If not, the claim is denied. This changes the target. The people this framework serves are not collecting benefits for addiction. They are people with a genuine disabling condition **and** a substance problem, sitting in a gap where the disability system does not treat them and the treatment system does not sustain them. **LINTEL fills a gap. It does not close a loophole.** That is a stronger position, not a weaker one, because it is true and because it does not require taking anything away from anyone. ### The real barrier Follow-up research on the 1996 cohort found that many former beneficiaries appealed and were recertified on the basis of mental illness, and examined whether substance use rose and treatment participation fell once the treatment mandate and representative-payee requirement were removed. Removing the benefit did not produce recovery. It produced re-filing. The barrier that actually holds people in place is the **benefits cliff**, and specifically the health-coverage half of it. In the 2015 National Beneficiary Survey, 27.9% of nonworking beneficiaries cited not wanting to lose cash or health benefits as a reason for not working. Liu and Stapleton found that 28% of a 1996 award cohort were employed at some point over the following decade, but only 6.5% ever had benefits suspended for work. Roughly one-half of one percent of beneficiaries per year have benefits terminated because of work. That gap — between how many work and how many ever cross the line — is the shape of the problem. People work up to the edge and stop. **The framework must be honest that the behavioral evidence is contested.** The Center on Budget and Policy Priorities concluded there is little hard evidence that the cash cliff keeps large numbers of beneficiaries from working to their potential. Both things are true: the fear is thoroughly documented, and the measured effect on behavior is not settled. GAO's 2024 assessment names three persistent disincentives rather than one — loss of cash and medical benefits, overpayments, and rule complexity. Rule complexity may be the largest of the three, and it is the one this framework is best positioned to attack. --- ## Part II — The Model ### The structural fact everything hangs on SSDI and SSI behave completely differently when a person works, and almost nobody in either program understands the difference. **SSDI has a genuine cliff.** Nine trial work months at full benefit, then a cessation month, then two grace months, then nothing in any month counted earnings exceed substantial gainful activity — $1,690 in 2026, $2,830 if blind. Income can drop by the full check between one month and the next. **SSI has no cliff at all.** After the first $85 is disregarded, the payment falls by one dollar for every two dollars counted. It phases down to zero at roughly $2,073 a month in earnings and never drops off a step. Every piece of guidance, every counselor conversation, and every screen in the companion app routes down one of these two paths from the first question. Conflating them is the most common and most damaging error in benefits counseling. ### Four doors, not one form The framework does not ask a person which program they are in partway through a questionnaire. It gives each population its own entrance: | Door | Program | Population | |---|---|---| | One | SSDI | Insurance earned through work | | Two | SSI | Needs-based assistance | | Three | SSDI | Veteran, with VA compensation | | Four | SSI | Veteran, with VA compensation | The veteran doors are not a courtesy. **The arithmetic is different, and a veteran routed through a general door receives a number that is wrong.** - **VA disability compensation does not reduce SSDI.** There is no offset between the two programs. A veteran draws both in full, and the only thing that can stop the SSDI check is work activity — never the VA rating. On the SSDI veteran door, VA compensation is displayed as the income floor that survives the cliff, because that is exactly what it is. - **VA disability compensation does reduce SSI**, dollar for dollar after the $20 general income exclusion, because SSA counts it as unearned income. In 2026, roughly $1,014 a month of VA compensation reduces the federal SSI payment to zero. For many veterans the SSI question is therefore settled before earnings enter into it, and the honest thing is to say so on the way in rather than after an application. *Sources: SSR 80-18; SSR 82-31; crossover derived from the 2026 federal benefit rate and the general income exclusion.* Beyond the arithmetic, the separation is deliberate on its own terms. Someone who served did not arrive at this system the same way, and the entrance should not pretend otherwise. Identical tooling behind each door, separate thresholds where the law makes them separate, and a distinct front door in every case. ### Five components **1. Make the cliff legible before anyone steps toward it.** A person cannot plan around a rule they cannot see. The month-by-month projection is the core intervention: total income across four years, with the exact month the check stops and the exact size of the drop. Not a brochure. A number, on their own figures. **2. Lead with what is protected, not what is lost.** The single most documented fear is losing health coverage, and it is the fear the existing rules most directly answer. - **Section 1619(b)** continues Medicaid for SSI recipients after the cash payment reaches zero, up to a state threshold. In 2026 those thresholds run from $29,412 to $84,208. Where medical needs exceed the average, SSA can calculate an individualized threshold above the state figure using documented impairment-related work expenses and publicly funded attendant care. - **Medicare continues for at least 93 months** — seven years and nine months — after the trial work period ends for SSDI beneficiaries whose impairment continues. This runs whether or not the cash check stops. - **Medicaid Buy-In** programs operate in nearly every state, with income limits commonly around 250% of the federal poverty level and resource limits far above the $2,000 SSI limit. **3. Guarantee the way back.** Expedited Reinstatement allows a return within 60 months of termination without a new application, with up to 6 months of provisional cash benefits and health coverage during review, generally not repayable if denied. Within the 36-month extended period of eligibility, benefits are suspended rather than terminated — a month back under the limit restores the check automatically. While a Ticket is assigned and progress is timely, SSA does not initiate a medical continuing disability review. A person who knows they can come back will try. A person who believes the door locks behind them will not. **4. Build ownership, not placement.** For this population, self-employment has a structural advantage: SSA counts **countable net earnings after business expenses**, not gross receipts. A cleaning business grossing $3,000 a month with $1,400 in supplies, transport, and insurance is not a $3,000 month. For the first 24 months SSA applies three tests under 20 CFR 404.1575 — significant services and substantial income, comparability to unimpaired peers in the same community, and the worth of the work to the business. In a one-person business any services are significant; more than half of management time, or more than 45 hours a month of management, meets the threshold. After 24 months the simpler countable income test applies. Capitalization comes from four places: - **Plan to Achieve Self-Support** — the most powerful and most underused tool in the system. A PASS excludes set-aside income and resources from SSI counting, so a person keeps a higher check while saving for the thing that ends the check. It funds equipment, vehicles, training, and inventory against an SSA-approved business plan under POMS SI 00870.026. - **State vocational rehabilitation agencies**, funded through a federal-state match with a federal share of about 78.7%. - **VR&E Chapter 31 Self-Employment track** for veterans with a service-connected disability. - **Boots to Business and the 31 Veterans Business Outreach Centers.** **5. Where employment rather than ownership is the goal, use IPS and hold fidelity.** Individual Placement and Support is the most-researched supported employment model available. Across 28 randomized controlled trials it produced an average competitive employment rate of 55% against 25% for controls; a meta-analysis of 17 trials found participants 2.4 times more likely to be employed. The evidence is equally clear that major deviations from its core principles reduce the effect. Adopt it whole or do not claim it. ### On treatment: incentive, not condition Recovery belongs in this framework. Conditioning benefits on it does not. Mandated treatment reliably improves retention and completion — participants are two to ten times more likely to finish a program. It does not clearly improve actual substance use outcomes, and some studies find elevated overdose risk after discharge. Coercion buys attendance, not recovery. The legal position is more decisive than the clinical one. Florida's 2011 law requiring suspicionless drug testing of TANF applicants was struck down as a Fourth Amendment violation and affirmed unanimously by the Eleventh Circuit; before the injunction, 32 of roughly 7,000 applicants tested positive. Suspicionless testing requires a special need beyond the normal need for law enforcement, and states have not been able to show one. **The design rule: make recovery the path with the rewards on it, not the gate in front of the benefit.** Treatment participation earns PASS approval support, priority business capitalization, and peer-role eligibility. It is never a condition of eligibility. This is more defensible, better supported by outcome evidence, and consistent with the framework's own stated purpose — a healthier life and productive work, not forced labor. --- ## Part III — Funding Stack | Source | What it carries | Note | |---|---|---| | State VR agencies (WIOA Title IV) | Self-employment services, training, equipment | Federal share about 78.7% | | SAMHSA SABG and MHBG block grants | Treatment and recovery support | Existing state allocations | | Medicaid 1115 waivers | Supported employment, SUD services | State-by-state negotiation | | PASS (SSA) | Individual business capitalization | Beneficiary's own income, excluded from counting | | WIOA Titles I–III | Workforce system access | Underused by this population | | VR&E Chapter 31 | Veteran self-employment | Separate authority, same design | | WIPA projects | Benefits counseling delivery | Funding levels require confirmation | **A live policy window:** SSA's authority to pilot alternatives to the benefit cliff has expired. New authority was discussed at a September 2025 House Ways and Means hearing. A framework that arrives with a designed demonstration ready is positioned for that authority when it is granted. --- ## Part IV — National Strategy **Lane 1 — The tool.** Ship the calculator free to beneficiaries. Adoption is the argument; a person who can see their own cliff becomes an advocate for fixing it. **Lane 2 — The counselor layer.** Train peer benefits counselors, including beneficiaries themselves, alongside the formal Community Work Incentive Coordinator credential through WIPA projects. Lived experience plus accurate numbers beats either alone. **Lane 3 — The certification standard.** Certify programs that meet the framework: routes SSDI and SSI separately, leads with coverage protections, guarantees the way back, uses IPS at fidelity where employment is the goal, and does not condition benefits on treatment. This is the durable business and the durable policy lever. **Lane 4 — State legislation.** Benefits-counseling mandates at application and at every earnings report, plus state supplement smoothing. **Lane 5 — Federal.** A permanent SSDI benefit offset replacing the cash cliff with a gradual phase-out, on the SSI model. This is the fix that makes the rest of the framework smaller. --- ## Part V — State Model Bill 1. **Benefits counseling as a right.** Every disability beneficiary is offered a certified projection at application, at any reported change in earnings, and annually on request. 2. **Cliff disclosure.** Any state program that changes eligibility at an earnings threshold must disclose the threshold and the resulting income change in dollars, in writing, before enrollment. 3. **1619(b) notification.** Written notice of Medicaid continuation at the moment the SSI cash payment reaches zero — the point of maximum fear and minimum information. 4. **Medicaid Buy-In parity.** Where a Buy-In exists, resource limits are set at levels that permit business capitalization rather than at SSI levels. 5. **PASS navigation.** State VR agencies staff PASS plan development, with a target volume rather than an availability statement. 6. **Self-employment as a VR outcome.** Business ownership counts as a successful closure equal to placement. 7. **No benefit conditioned on treatment.** Recovery participation may earn priority and support. It may not gate eligibility. No suspicionless testing. 8. **IPS fidelity requirement.** Any state-funded supported employment program claiming the IPS name meets the fidelity standard or does not use the name. 9. **Data.** Annual public reporting of attempts to work, suspensions, terminations for work, and reinstatements, by program. --- ## Part VI — Metrics and the Falsification Condition Track: - Share of beneficiaries who receive a projection before their first earnings report - Attempts to work, as distinct from sustained work - Suspensions and terminations for work, separately - Expedited reinstatement requests and approvals - Business formations and 24-month survival - Medicaid retention through 1619(b), by state - PASS plans opened, approved, and completed **The condition that would falsify this framework:** if beneficiaries who receive an accurate cliff projection attempt work at the same rate as those who do not, then information was not the barrier and the framework's central premise is wrong. That result would point toward the cash cliff itself, or toward health and capability constraints, as the operative obstacle — and the response would be Lane 5 rather than Lane 1. This condition is stated in advance, on purpose. A framework that cannot say what would disprove it is advocacy, not policy. --- ## Part VII — Licensing Map BB2G LLC owns; nonprofits license. **Permanent free tier, written as an EULA term rather than as policy:** the LINTEL projection is free to the beneficiary, always. The person whose income is at stake never pays to see their own number. Revenue ranking: 1. **The LINTEL certification standard** — programs certified against the framework. Largest business, identical to Lane 3. 2. **Counselor training and credentialing** — the peer benefits counselor layer. 3. **State enterprise licensing** — agency-wide deployment with state-specific data. 4. **Data subscription** — the state threshold and Buy-In table, maintained. **Contract cautions:** - Never sell LINTEL as a benefits determination. It is a projection on user-supplied figures. SSA decides cases. - Government sales require a procurement vehicle. - Section 508 compliance is a procurement advantage, not only an ethic. - Pricing is counsel's question. No figures are assigned here. --- ## Open Items | Item | Status | |---|---| | 1619(b) thresholds, 48 of 52 jurisdictions | Open — queued, not estimated | | Separate blind thresholds (four states have one; which four) | Open | | Medicaid Buy-In presence and terms by state | Open — national counts conflict | | ADA and Rehabilitation Act limits on conditioning benefits on treatment | Counsel question | | PASS active enrollment count | Open | | TWP self-employment hours test | Unverified — confirm against POMS | | ABLE to Work contribution cap for 2026 | Unverified against IRS primary source | All 2026 SSA figures change each January with the cost-of-living adjustment. Re-verify the full figure set between October and December 2026.