| Action | Money Follows the Person |
| Stage | Fast-Track |
| Comment Period | Ended on 4/2/2008 |
 |
42 comments
I have an objection to the above mentioned proposal. The basis of my objection is stronly planted in concern for consistent and quality services to all consumers/customers. The task at hand is a challenging one that relies on trained and prepared individuals to provide services. The need for quality, and consistency is important in providing continuity and this impacts not only the consumer but the employer as well.
Providing Employment Services to individuals with disabilities requires extensive and specific training, knowledge, skills and abilities. There is a whole range of skills, such as; assessment, job development, knowledge of accommadations, job-site training (step-by-step training) and specific knowledge of the employers requirements for the job. Knowledge of the individual, the attributes of the specific disability and experience in the job market. The skills required to place individuals into jobs can only be gained through on-going training and experience. Because individuals with disabilites are historically, under employed, staff using best practices and methods should provide services.
Respectfully,
Linda St.Clair
XO
I have an objection to the above mentioned proposal. Trained professional employment specialists assist persons with disabilities to achieve a better life through finding work in the community. The need for quality and consistency is very important in providing consumers and employers the best service possible. Trained Employment Specialists assist consumers with all phases of job searching as well as step by step training on the job which requires specific knowledge of the employers requirements.
Respectfully,
Bonnie Quesenberry
bquesenberry@goodwillvalleys.com
The Supported Employment Program was designed to assist individuals with disabilities find and maintain meaningful employment. The program has help shaped and changed many lives. The program has been such a success because the program has provided good quality of service to those seeking assistance. In order for this program to continue to be successful, the staff members must continue on going training to increase success and satisfaction for the individuals involve in the program.
Tammy Nguyen
I object to the proposed waiver services section 12 VAC 30-120 due to this will allow untrained professionals to come in and work with any disabled person wether they have a disability of a physical handicapp, mental illness, or substance abuse. As a person with a mental health degree I find it very useful in the field to determine problems on the job to be part of the persons disability due to being mentally ill or an actuall problem on the job site. An untrained person would not be able to detect the differences and may cause injury to the mentally ill person and/or loose the persons employment. I also oppose this waiver due to an untrainied person would not have the knowledge to handle the medical aspects of a disabled person on the jobsite. If a disabled person was to have a seizure and a untrained person was on the jobsite the disabled person may again become injured or if the seizure is severe enough death. The training I have recieved helped me to be able to respond more accurately to any jobsite conflict that may arise. Also through the training I have recieved I learned about certain accomadations needed to potential worksites. An untrained person would not have this knowledge and would again possibly cause injury to the disabled person or loss of employment. One final point an untrained person would not have the knowledge how to take care of certain issues on the job such as sexual harrassment or abuse by a family member or an employer. This would be like going to a regular medical doctor only to find out he only had a G.E.D.! The disabled have the right and have deserve a trained person to help them and support them with employment.
I object to the proposed waiver services section 12 VAC 30-120 due to this will allow untrained professionals to come in and work with any disabled person wether they have a disability of a physical handicapp, mental illness, or substance abuse. As a person with a mental health degree I find it very useful in the field to determine problems on the job to be part of the persons disability due to being mentally ill or an actuall problem on the job site. An untrained person would not be able to detect the differences and may cause injury to the mentally ill person and/or loose the persons employment. I also oppose this waiver due to an untrainied person would not have the knowledge to handle the medical aspects of a disabled person on the jobsite. If a disabled person was to have a seizure and a untrained person was on the jobsite the disabled person may again become injured or if the seizure is severe enough death. The training I have recieved helped me to be able to respond more accurately to any jobsite conflict that may arise. Also through the training I have recieved I learned about certain accomadations needed to potential worksites. An untrained person would not have this knowledge and would again possibly cause injury to the disabled person or loss of employment. One final point an untrained person would not have the knowledge how to take care of certain issues on the job such as sexual harrassment or abuse by a family member or an employer. This would be like going to a regular medical doctor only to find out he only had a G.E.D.! The disabled have the right and have deserve a trained person to help them and support them with employment.
As an individual who has worked in the field of Vocational Rehabilitation and has managed a staff of Supported Employment professionals for over ten years, I am strongly opposed to the current language in the proposed Money Follows the Person (MFP) Fast Track Regulations - Waiver Services 12 VAC 30-120. The minimum requirements listed in the proposed regulations for Supported Employment providers are far below the industry standards, and far below the professional standards for RSVP, Inc., the company for whom I work. At the current time, RSVP, Inc., as well as other Employment Service Organizations in the state of
Also, services provided by Supported Employment Specialists who work for RSVP, Inc.'s Supported Employment program are nationally accredited by CARF. Accreditation by CARF indicates an organization has substantially conformed to CARF standards that are designed to benefit the persons served. Individuals who possess less than the above mentioned experience and education would not be conducive to allowing RSVP, Inc. to continue to meet and exceed the national standards set by CARF. Furthermore, CARF Accreditation is a mandatory standard for organizations that provide Supported Employment services for the Department of Rehabilitative Services in the
Please strongly consider changing the language in the proposed Money Follows the Person (MFP) Fast Track Regulations - Waiver Services 12 VAC 30-120. This will help us to protect the integrity of professionals in the field of Supported Employment as well as the quality of the services that we provide for persons with disabilities.
Thank you,
Manager of Supported Employment Services
RSVP, Inc.
I am writing to support my opposition to the proposed Waiver Services - Section 12 VAC 30-120. As a provider of Supported Employment services, I am aware of the need for specialized education and training in order to best serve SE clients in order to produce the most effective services. The needs of our clients cannot be adequately met by someone with the minimum skills listed under these Fast Track Regulations. I urge you to reconsider the proposed Waiver Services - Section 12 VAC 30-120 in order to provide clients with the specialized services that they deserve.
I would like to be kept informed of the progress of proposed Waiver Services - Section 12 VAC 30-120 and can be reached at Ericka.Umbarger@thechoicegroup.com.
Sincerely,
Ericka Umbarger, MSW
The Employment Assistant is not a qualified Supported Employment professional by the definition in the proposed regulations. This could seriously damage the Supported Employment opportunities that we are trying to create for persons with disabilities.
The regs for consumer directed services should indicate the same qualifications as the Agency directed services while still allowing the individual the opportunity to direct their own services. Anything less is detrimental to the consumer.
Thank you,
I am writing to support my opposition to the proposed Waiver Services - Section 12 VAC 30-120. As a provider of Supported Employment services, I am aware of the need for specialized education and training in order to best serve SE clients in order to produce the most effective services. The needs of our clients cannot be adequately met by someone with the minimum skills listed under these Fast Track Regulations. I urge you to reconsider the proposed Waiver Services - Section 12 VAC 30-120 in order to provide clients with the specialized services that they deserve.
I would like to be kept informed of the progress of proposed Waiver Services - Section 12 VAC 30-120 and can be reached at matthew.deans@thechoicegroup.com
Sincerely,
Matthew Deans, BA
I am writing to express my strong opposition to the proposed Waiver Services - Section 12 VAC 30-120. As a provider of Supported Employment services, I am fully aware of the need for specialized education as well as extensive and on-going training in order to best serve SE clients. Individuals meeting the proposed base requirements listed under these Fast Track Regulations may not necessarily be adequately equiped to provide the supports necessary for the clients served. The needs of the client must be met by trained and qualified service providers; otherwise, the intended "service" may be rendered a disservice. I urge you to reconsider the proposed Waiver Services - Section 12 VAC 30-120 in order to provide clients with the specialized services that they deserve.
I would like to be kept informed of the progress of proposed Waiver Services - Section 12 VAC 30-120 and can be reached at Richard.Lucyshyn@thechoicegroup.com
St. John's Community Services-Virginia has considerable concerns regarding the proposed Fast Track Waiver Services regulation. Given the many years of experience providing Supported Employment and other services, it is our current position that consistency cannot be maintained utilizing industry accepted and proven effective practices by those individuals who do not share the same level of training, education and credentials necessary to provide the service.
In addition, persons receiving Supported Employment services from qualified professionals benefit significantly. Use of a professional Employment Support persons when developing the employee/employer relationship can be invaluable and also embraces the ability for the individual to actively participate and direct their own services. The development of these relationships through "natural supports" requires a professional skill-set. The SE support professional understands what role they play in ensuring that both the individual and the employer needs are mutually met in efforts to offer and maximize opportunities for people interested in working.
Please be assured that St. John's Community Services-Va is always willing to embrace concepts and services which will best serve and present additional opportunity for the people we serve as well as those we do not. Please delay and investigate the long-term impact this regulation will have on the system.
Thanks You for your Consideration,
Thalia Simpson-Clement, tsimpsonclement@sjcs.org
As a provider of Supported Employment Service, I strongly oppose to the proposed Waiver Services - Section 12 VAC 30-120. Our clients need professional attention due to their mental and physical situations; this job is not design for just any individuals. The Supported Employment Program throughout the years has been successful by providing services for those individuals with disabilities.
tatiana.fetgo@thechoicegroup.com
I am writing to support my opposition to the proposed Waiver Services - Section 12 VAC 30-120. As a provider of Supported Employment services, I am aware of the need for specialized education and training in order to best serve SE clients in order to produce the most effective services. The needs of our clients cannot be adequately met by someone with the minimum skills listed under these Fast Track Regulations. I urge you to reconsider the proposed Waiver Services - Section 12 VAC 30-120 in order to provide clients with the specialized services that they deserve.
LaWanda D. Jones M.S.,C.R.C
As a provider of Supported Employment Services I strongly object to the proposed Waiver Services - Section 12 VAC 30-120.
Best practices within Supported Employment services dictate a need for qualified professionals to assist the individual in search of employment as a means of reaching their full postential in the community. The current proposed requirements for individuals to provide consumer directed SE services are indadequate. Supported Employment is a nationally accredited CARF service. CARF includes the minimum requirements necessary to carry out this service. Adequate training and qualifications are essential in order to maintain the integrity of the SE profession within the business community. A bad experience within the business community can have negative impacts resulting in fewer job opportunities available to individuals who benefit from inclusion and integration through employment.
Waiver participants utilizing the consumer directed SE service deserve the same quality that other participants of SE services enjoy.
Regards,
Goodwill of
Providing Supported Employment services requires an extensive skill set.
Because the desired outcomes are employment and job retention it is essential that those providing supported employment have job development and training skills and experience as well as access to community employers and other employment resources. Gaining access to community employers can at times be difficult for trained, seasoned professionals. Individuals lacking the experience and most importantly connections with the business sector would struggle to achieve employment outcomes that are based on consumer needs, abilities, desires and preferences. Secondly, a Supported Employment professional must have excellent communication and negotiation skills as well as the ability to quickly develop rapport with an array of human services professionals, employers and other persons connected to the person receiving the service. Finally, the Supported Employment professional must remain current regarding community labor trends and best practices in the field.
For the reasons stated above, it is our opinion that the proposed minimum requirements, i.e. Basic English, high school diploma, negative TB Test, etc. will have a negative impact on the quality of services delivered to waiver consumers. The Supported Employment Program has operated successfully in
Sharon B. Taylor
Vice President of Education & Training
Goodwill of
Email Address: sbtaylor@goodwillcva.org.
We are writing to state our objection to the Proposed Waiver Services Section 12 VAC 30-120 VA-APSE is a statewide association engaged in the business of advocacy and education to improve and expand integrated employment opportunities for Virginians with severe disabilities. We are a chapter of the National Association of Persons in Supported Employment. Our Board of Directors voted at its recent meeting to oppose the Fast Track Regulations for the MFP Demonstration project. Knowing the importance of this demonstration project to people with severe disabilities across the Commonwealth, we take this action with much consideration. We hope that DMAS will halt the Fast Track process and proceed instead with Emergency Regulations, thus allowing the demonstration project to begin as now planned on July 1, 2008. VA-APSE is very supportive of consumer-directed services, including Supported Employment services. Our greatest concern is with the definition of “Employment Assistant” under the proposed regulations for Consumer-directed services - Supported Employment option. This classification of worker, with its minimum level of requirements and no required supported employment training, will have a negative impact on both the quality of services to waiver consumers as well as to the profession of Supported Employment. Regulations for Consumer-directed services should parallel the requirements for Agency-directed services. Supported Employment Specialists /aka Job Coach is not a paraprofessional position as with some other consumer-directed services. A large percentage of Job Coaches in Virginia are Masters level professionals. Supported Employment is a nationally accredited CARF service titled Community Employment Services that includes Job Supports, Job Development, and Job-Site Training. CARF defines the minimum requirements for a Supported Employment Specialist / Job Coach. Further, in Virginia, the Department of Rehabilitative Services requires that all of its vendors of Community Employment Services – Supported Employment – meet these CARF requirements. We ask that the MFP regulations include these same standards of training and excellence. VA-APSE supports training for job coaches to earn a National Certificate in Employment Services as approved by the Association of Community Rehabilitation Educators. We are not asking that this certification be a requirement in the MFP regulations. We only mention this to emphasize the fact that Supported Employment services are designed to respond to the employment needs of people with the most severe disabilities, and as such, require skilled professionals who are knowledgeable of the needs of people with disabilities, the employment market and the business sector. We ask again that you halt the Fast Track process and work with organizations such as VA-APSE and vendors of Supported Employment to design regulations that more accurately reflect the standards and best practices of Supported Employment in Virginia. Thank you for your consideration. Sincerely, Joanne Packert, President Virginia Association of Persons in Supported Employment J_Packert904@msn.com
I object to proposed Waiver services 12 VAC 30-120. Specifically I object to CD Supported Employment services option as it relates to provider requirements. The delivery of supported Empoyment services requires specialized knowledge and skills. Please consider changing the language of the proposed regulation to include provider requirments of either experience in providing Individual Supported Employment services with a CARF accreditated organization or national certification in Supported Employment. This will protect the individuals receiving the service and the integrity of the profession. Both are important to the individuals funded through this Waiver and the future availability of placements for all individuals using Individual Supported Employment services.
March 25, 2008
Brian McCormick, Regulatory Supervisor
Department of Medical Assistance Services
Dear Sir,
Rappahannock Goodwill Industries would like to express our objection to the CD Supported Employment service option as proposed in Fast Track Regulations – Waiver Services 12 VAC 30-120. While supportive of consumer-directed services, the proposed fast track regulations to Supported Employment are not sufficient to maintain the current integrity and specialization of individual supported employment nor the direct service professionals themselves.
Our inability to support this measure is based upon the lack of training required for the direct service providers. Individual Supported Employment is a unique mission that requires specialized training and experience. The level of training required is evidenced by the fact that Supported Employment has a national certificate offered through federally funded RCEPs. Additionally, Supported Employment is carefully monitored and appropriately accredited by CARF.
Historically, the relationship between competitive employers and the Supported Employment program has been tenuous at best. A negative experience with a provider can not only jeopardize the acceptance of that one employer but that one employer often will share that experience with their colleagues. The industry’s reputation is continuously at stake.
Quite possibly the greatest challenge for these professionals is the balance between the expectations of the business community and the individual needs of the participants. Only a fully trained, competent employment specialist can provide such skilled services.
Finally, Waiver participants choosing the option of CD Supported Employment should be afforded the same level of SE expertise, knowledge and experience that other participants enjoy.
Thank you for the opportunity to comment. For questions please contact
Sincerely,
C. W. Van Valkenburgh
President/CEO
cc: vaACCSES
I have an objection to the proposed Waiver Services-Section 12VAC 30-120. Supported Employment professionals and agencies work hard to maintain the integrity of the services that are provided to the business community. The business community expects a certain level of professionalism as well as service delivery to meet their employment needs. The industry’s reputation is continuously at stake. One bad experience with an employee in a Supported Employment model can jeopardize the relationship with that employer and can lead to other employers not wanting to hire someone else who uses the Supported Employment model, often employers will share their bad experiences with other colleagues. This said, CD SE providers should have the same qualifications and requirements as agency directed SE professionals. My email address is vrhame@goodwillcva.org
I object to the proposed Waiver Services - Section 12-VAC 30-120. Supported Employment is a professional service. A Job Coach is considered a specialized profession that requires training in order to assist individuals with severe disabilities achieve successful employment outcomes. The proposed waiver services will diminish the professionalism of this service for the individual as well as the business community. Service providers in the field have worked very hard with the business community helping them see the benefits and value of hiring an individual with a disabiltiy to meet their employment needs. We present ourselves in a professional manner, our job coaches have a bachelor or masters degree, are covered by professional liability insurance, workers compensation and are paid a decent wage in order to ensure consistency and stability for our customer and the business' who hires our customers. The business community expects a professional level of expertise and the assurance of the insurance protection that they get with working with a professional Employment Service Organization.
To Whom This May Concern,
I have an objection to proposed Waiver Services- Section 12 VAC 30-120. ICON Community Services provides skilled job coaching services from professionals who have been educated and trained in how best to assess an individual's strengths and talents to ensure that they find the right job in the community. Job Coaching is a profession that requires a multitude of skills that must be learned through focused education, training and continued support. The end result is quality service and the successful achievement of goals. On behalf of all of the staff and the hundreds of people we support in the community, I thank you for your attention to this matter.
I object to the proposed Waiver Services Section 12- VAC 30-120. The proposed waiver services will jeopardize the quality and integrity of supported employment services among customers and employers who currently use this service. Job coaches are trained professionals who specialize in providing supported employment services to individuals with disabilities and have gained respect among employers in the community by providing services in a professional and consistent manner. Employers are attracted to the benefits of working with professional Employment Services Organizations such as highly qualified job coaches providing on and off-site support, liability insurance offered by ESO's, and the professional communication that occurs among all parties in regards to placements. Employers have grown to expect and appreciate the professional level of services that Employment Services Organizations offer. Most importantly, customers are more adequately served by trained, professional staff, who come from ESO's that have met the stringent requirements outlined by CARF and that follow "best practice" in terms of service delivery.
Comments – RFP Fast Track Regulations – Waiver Services 12 VAC 30-120
MVLE, Inc. is supportive of the concept of consumer directed services including Supported Employment. However, the proposed fast track regulations that establish Supported Employment as an established service are not adequate to preserve the current integrity and specialization of Individual Supported Specialists / Job Coaches as direct services professionals.
The current regulations, as written, are inadequate and do not reflect “best practices.” Consumer Directed Supported Employment providers should have the same qualifications and requirements as agency directed Supported Employment professionals.
Finally, Consumer Directed participants deserve the same level of Support Employment expertise and knowledge that others utilizing this important service currently enjoy.
April Pinch-Keeler, President
MVLE, Inc.
I am writing to express my objection to the proposed Money Follows the Person Fast Track Regulations. Supported Employment service providers have worked hard to establish core competencies and training for the Employment Specialists who provide these services. The current proposed regulation disregards these requirements and instead establishes minimal requirements that have nothing to do with the person's ability to provide support to all stakeholders.
The core competencies for an Employment Specialist include the ability to conduct in-depth assssments of an individual's vocational strenghts and barriers. This is done through observations in community-based employment settings. The ability to complete a job anaysis and task analysis for training is essential. Developing and maintaining relationships with the business community in order to match a prospective employee to a job is crucial. The abilitiy to listen to and communicate with the individual, the employer, the case manager, the family and any other person who is part of the team is necessary. Problem soving skills and the ability to anticipate them is critical to the long term employment success.
These skills far exceed the minimum requirements as outlined in the proposed regulations. While I am supportive of consumer-directed services including consumer-directed supported employment, I can not support a regulation that allows for the provision of second rate services to individuals who deserve much more than they often recieve.
Christine Heiby
cheiby@iconservices.org
MQ
Supported Employment is a nationally accredited CARF service titled Community Employment Services that includes Job Development, Job Supports and Job-Site Training as well as the minimum requirements for a Supported Employment Specialist (SES) or Job Coach.
The proposed regulations do not support SE as a professional service requiring the same high level professionalism as required by CARF and, in effect, diminishes the profession and the quality of services. Waiver participants participating in the Consumer Directed SE service should be afforded the same level of SE expertise, knowledge, and professionalism that other Waiver participants enjoy.
March 28, 2008
Brian McCormick
Regulatory Supervisor
Department of Medical Assistance Services
600 East Broad Street, Suite 1300
Richmond, VA 23219
Dear Mr. McCormick:
I am strongly opposed to the proposed Waivered Services [12 VAC 30 - 120] for a multitude of reasons. Most importantly, I am sincerely concerned that the proposed regulations will have a detrimental effect on individuals with disabilities who are seeking to obtain and maintain employment in the community. Those providing direct service in the field of supported employment are professionals and they have specific qualifications and experience that are critically essential to the provision of quality services.
In the Commonwealth of Virginia, organizations that provide supported employment services through the Department of Rehabilitation Services are required to maintain accreditation with CARF - the Commission on Accreditation of Rehabilitation Facilities. One of the cornerstones of CARF accreditation is outcomes measurement. Accordingly, CARF-accredited programs continually seek to measure and to enhance the quality and effectiveness of their supported employment services.
Consumer choice is at the center of all CARF accredited services. While supported employment services are tailored to the individual needs of each consumer and the requirements of the employer, supported employment professionals have experience working with other consumers and they utilize best practices in the field. The relationships and partnerships that they have been developed with employers are frequently critical to success of consumers.
Beyond the accreditation requirements, most individuals who are actively engaged in supported employment have specific training and experience in working with people with disabilities and in job placement activities. Many pursue specialized training in supported employment through courses, seminars and workshops. Additional educational and networking opportunities are available through vaACCSES - the Virginia Association of Community Rehabilitation Programs, the Virginia Association of Persons in Supported Employment and the Virginia Rehabilitation Association.
WorkSource serves approximately 450 citizens with disabilities from the City of Charlottesville and Albemarle, Fluvanna, Greene, Louisa and Nelson counties. With the assistance of WorkSource employment specialists, 320 consumers worked at 88 different during the year ended June 30, 2007.
As the current President of vaACCSES, I am also very familiar with the great work done by other supported employment vendors throughout the Commonwealth. Individuals with disabilities deserve the right to chose providers of supported employment services who are knowledgeable, experienced and qualified. Unfortunately, that cannot be assured with the proposed regulations.
Sincerely,
Charles J. McElroy
President & CEO
cc: Karen Tefelski
Executive Director
vaACCSES
Although I support the intent of the MFP regulations I strongly object to its regulations concerning Supported Employment services.
First, Supported Employment providers must meet stringent requirements from State agencies in order to bill for services. Those requirements ensure that the services rendered to persons with disabilities are effective –that they achieve what they are meant to achieve; efficient – that they make the best possible use of taxpayer monies by achieving results in a timely manner; and accountable –that when providers consistently fail to render services that are effective and efficient State agencies exercise the option of no longer doing business with them, thus ensuring that other persons with disabilities are not subjected to substandard services. Although under Consumer Directed services individuals with disabilities have the option of "firing" a provider who is not delivering proper services, there is no way of tracking down the performance history of any individual who provides poor services, thus exposing other persons with disabilities to the same incompetence. Moreover, the tremendous amount of time and money that State agencies dedicate to the development and tracking of outcome measures would be negated by a system where any untrained individual can provide a service that requires specific knowledge, skills and abilities to properly serve some of the Commonwealth's most vulnerable citizens without being accountable for the results.
Second, the extremely broad and general requirements for a person to provide Consumer Directed Supported Employment do not incorporate the depth and breadth of knowledge, skills and abilities that Supported Employment professionals must possess to obtain successful outcomes for the persons served. Among many others, for a person with a disability to be well served, professionals in the field of Supported Employment must have knowledge of medical, sensory, psychological and psychiatric issues to identify and develop proper support systems, including adaptive technology, and he or she must understand the impact of employment income on government benefits and entitlements. He or she must have outstanding people skills to work effectively with a wide variety of people, as well as good communication in writing and orally to ensure there is a track record of the services provided to the client. SE professionals must have the ability to work well with the individual's coworkers and supervisors to ensure that she is well integrated and supported at the site once the job coach leaves. MFP allows for payment to coworkers. This, though well intentioned, destroys the principle behind natural supports, does not mesh with the reality of worksites with high turnover, and worst, diminishes the image of the worker with a disability as a member of the team, who is supported and valued by ALL other team members, not only the one being paid. The idea of paying a natural supporter does little for integration; in fact, it would encourage isolation. Lastly, SE professionals must have the ability to coordinate the requirements that the supported employee must meet at the job with other services he or she may be receiving. For employment services to be effective, the myriad details that must be arranged and monitored at the client's worksite to ensure his or her success and health and safety must take place at the source, in a timely manner. Neither of these elements can be properly addressed by a case coordinator removed from the day to day reality of the client's workplace.
Thirdly, currently, SE providers are expected -and often, mandated- to attend trainings that develop and sharpen the knowledge, skills and abilities needed to ensure the success, health, and safety of individuals with disabilities in the workplace. These trainings also develop an attitude of respect, self-assurance, poise, and professionalism essential to the image that SE providers project to the business community. Business people are assured that when they allow a job coach to help a worker with disabilities learn the job, that job coach is sensitive to the needs of the business, knowledgeable about the needs of the worker, and capable of handling any crisis that arise on the job. Moreover, business people are assured that the job coach will not present a liability to the business if he or she where injured at the worksite, because the job coach is covered under their employer's Workers Compensation plan. In addition to potentially weakening the professional image earned through meeting stringent national accreditation and State requirements, the MFP regulations for SE Waiver severely erode the trust of employers willing to hire persons with disabilities because they are reassured by the level of professional support provided to the person and the fact that their business would not be liable for injury to the job coach. One very negative experience would be enough to ruin the hard earned reputation of professional Supported Employment providers, and by extension, the image of persons with disabilities as valuable additions to any workforce, as well.
As written, these regulations do not provide for any accountability towards the State, the taxpayer, and least of all, towards the person in need of services and the businesses willing to give him or her the opportunity to become a valued member of the workforce. I urge you to strike the provisions related to Supported Employment and work closely with SE professional organizations in crafting regulations that capture the spirit of MFP while avoiding the dangerous pitfalls in the current language. Most unfortunately, they exemplify the unintended negative consequences that can result from the best of intentions.
Thank you for the opportunity to comment on the regulations for Waiver Services – Section 12 VAC 30-120.
Respectfully,
Carmen I. Mendez
MHMR Supervisor II
VB
cmendez@vbgov.com
My argument is that for the SE professional to adequately provide service to consumers to better their career goals, it is important that it be done by qualified people trained in career transitions. This knowledge exemplify that a person has mastered a specific set of knowledge, demonstrated skills and abilities, as well as having the authority to address certain issues. Having experience and formal training also implies provisions for competent service in the specified area, with integrity. This provision would prove to be immeasurably valuable to any consumer or client. Having these established standards for knowledge, skills and practice means that the customers are protected and the needs of the employers and the community are met as well.
I object to the propoed Waiver Services for CD Supported Employment.
Job Discovery, Inc., is supportive of consumer directed services. However, in the context for CD Supported Employment services, the standards will be lowered and non-inclusive of adequately reflecting best practices within Supported Employment.
It is imperative that future delivery of Supported Employment Service and the integrity that goes along with this concept is not compromised, which includes the professional training and expertise by an Employment Specialist (Job Coach) to assist the individual in their employment of choice as well as the inclusion of the community and its natural supports (not paid supports).
Job Discovery, Inc. provides continuous trainings to the Employment Specialists, and has a full accreditation by CARF which supports Community Employment, Job Development, Job Supports and Training Services. This requirement must also be afforded to persons of Waivers Services for CD Supported Employment.
I object to the proposed waiver services section 12 VAC 30-120. Professionally trained employment specialists have proven to be beneficial in helping persons with disabilties locate and maintain employment in the community, which in return helps them become independant and feel like a productive part of society.
I object to proposed waiver services section 12 VAC 30-120. As a Supported Employment Specialist , I know and understand how important it is for the consumer to have someone working with and for them who is knowledgeable in all aspects of Supported Employment. These include training and skills to complete assessments, aide in job training, knowledge of employers requirements for job openings and any accommodations needed for the consumer to be successful in employment. A trained Employment Specialist knows specific disabilities and knows how to communicate with each consumer according to his/her needs. If a support person is not trained in first aide they will not be able to respond properly to medical emergencies should they arise. In order for persons with disabilities to succeed they must have a trained specialist who will not set them up for failure.
I oppose this legislation. NW Works personnel working in this area are specially trained. They have developed trusted relationships with employers in the community so that these employers now feel confident in providing employment for an adult with a disability. The employer knows that should problems arise, they can come back to our job specialist who will then take the time to assist both the employer and the person employed.
If unqualified individuals start trying to provide these services, great strides in employing adults with disabilities will be lost. Positive relationships with employers could be damaged, and with that future employment opportunities.
CRP's in Virginia must be CARF certified in order to receive compensation from DRS for provision of Supported Employment Services. Given that, any person providing Supported Employment services should be held to the same standard. This legislation could result in disabled adults losing ground in the employment arena through no fault of their own.
Sincerely,
Luana Murray
As a long time provider to and employer of individuals with disabilities, I strongly oppose the proposed Waiver Services Section 12 VAC 30-120. While I whole-heartedly support consumer directed services, the proposed Fast Track regulations will not protect and serve this all-too-vulnerable population.
All providers of services to clients with disabilities should meet a standard of care and training to ensure that safe, reputable and outcome-oriented services are provided. From the provider prospective, this is done through education, training and certification, all of which is reviewed via direct supervision, and ultimately, the CARF accreditation process. The proposed "Employment Assistant" will not best serve our disabled partners because not of these standards and systems of oversight will be in place. I for one can not support a system that could be detrimental to our client's recovery and possibly slow or halt their re-entry into the community.
Thank you in advance for your time and attention to this matter.
John Brauer, CEO
NW Works, Inc.
I object to the proposed waiver services section 12 VAC 30-120. This proposal will allow an untrained individual the rights to work with disabled and challenged people. We don't hire untrained teachers to teach our children in school or doctor's with no medical degrees. Disabled people require special needs and attention that can only be learned thru a great deal of training. I speak from experience as I was a brother of a disabled sister and as such I would have never allowed someone that was not trained or with a great deal of experience to help or aid her in any way. It takes years of hands on experience and classroom training to even come close to understanding all the special skills and task needed to help the disabled. By doing this it takes away the RIGHTS disabled americans have to get the best possible help that they need and deserve.
As the President and CEO of an Employment Services Organization and as a provider of supported employment services for over 20 years and with a staff of 25 job coaches, I am strongly opposed to the current language in the proposed Money Follows the Person (MFP) Fast Track regulations-Waiver Services 12 VAC 30-120.
While The Choice Group is totally in favor of consumer directed services we are strongly opposed to the minimum requirements to qualify as an Employment Assistant. The consumers served through supported employment have numerous barriers to employment requiring a level of experience and education commensurate with the needs of the consumers. These consumers are typically some of the most vulnerable citizens of the Commonwealth of Virginia and anything less than a qualified supported employment provider would certainly be detrimental not only to the consumers, but also to the businesses we have spent many years building professional relationships with.
I would propose requirements be equivalent to what is already required by the CARF accredited Employment Service Organizations in the Commonwealth of Virginai who have been successfully serving consumers since the 1980's.
Thank you for your consideration.
I object to the porposed Waiver Services- Section 12- VAC 30- 120. Supported Employment is a professional service provided by trained professionals. A job coach is considered a specialized profession that requires an extreem amount of training in order to successfully assist individuals with severe disabilities to find successful, meaningful employment in the community. The proposed waiver services will diminish the professionalism of the service for the individual as well as the business community. Service providers in the field have worked diligently with the business comminuty helping them to see the benifits and value of hiring an individual with a disability to meet their employment needs. We present ourselves in a professional manner, our job coaches have a Bachelor or Masters Degree, are covered by professional liability insurance, workers compensation and are paid decent wages in order to ensure consistency and staility for our customer and the business' who hires our customers. The business community expects a professional level of expertise and the assurance of the insurance protection that they get when working with a professional Employment Service Organization.
My name is Ellen Davidson. I am a board member for St. John's Community Services.
I have been supported by a professional Supported Employment stadd since I started working at Fort Belvoir in 1992. When I graduated from high school St. John's Community Services worked with me and the supervisors and staff to make surre that I was able to do my job. I have always worked with professional staff. I don't think that I could have done it without people who were trained to do their job. I oppose the Fast track MFP Regulation.
Thanks,
Ellen Davidson
Protocol Office, Defense Acquisition University
Fort Belvoir
I am very supportive of consumer-directed services including Supported Employment (SE) services. However, the proposed fast track regulations that establish this service as a Consumer-Directed service are not adequate to preserve the current integrity and specialization of individual Supported Employment itself and Supported Employment Specialists (SES)/ Job Coach as a direct services profession. As an Employment Specialist working in this field, I am appalled at the proposed regulations for an individual that could potential provide services. I have obtained a bachelors degree in the field, spend many hours training for my job and continue to attend trainings to further my understanding of this service profession. As a job coach, employed by an Employment Service Organization, I am provided with the supports to be able to assist individuals with disabilities and as an organization, we have established "best practices" and standards to provide the utmost of quality service for the individuals we serve. I object to the proposed waiver.
After considerable discussions and review of the proposed changes and comments concerning the DMAS Fast Track Consumer Directed SE Option, I can appreciate the comments and views which have been expressed that have voiced objections to the proposal as drafted and moreover, the desire for additional consumer directed community based services.
In 1997, DRS took the position that all vocational services offered through our own agency’s Employment Services Organizations would be nationally accredited; this included the Supported Employment program. The consumers accessing these vocational services are not only our most significantly disabled, but also are often the most vulnerable. It is important that these individuals receive quality driven, effective & efficient services, which are based on consumer choice.
Some issues for which DRS has some degree of concern are presented below:
1. Is the “employment assistant” service in the Consumer Directed Supported Employment program intended to be and / or comparable to the Supported Employment services purchased by DRS?
2. For training of the “employment assistant”, who would conduct the training, what would the training consist of and who would pay for the training?
3. Will a case manager develop the ISP for the individual and ensure the “employment assistant” meets some level of minimum requirements?
4. Will the case manager be the “gatekeeper” for the service?
5. Will the fee for this service be comparable to DRS rates for the Supported Employment individual model as recently cited in the Commonwealth’s budget document?
6. DRS requires monthly contacts with either the consumer or employer once the person is stable in employment and requires “follow along” services. Presently the average monthly hours for the service per individual is 3.5. Will the “employment assistant” be required to maintain monthly contact to ensure employment is maintained and at what level of intervention; and is there a monthly expectation of the numbers of hours to be sponsored by DMAS funding?
DRS feels that addressing the more than 40 concerns cited already and discussion of the items cited above is an essential part of this most important process which will ultimately allow a significant increase in the employment of so many Virginians with substantial disabling conditions.