Wright Choices, Inc. is a strong community advocate for employment for persons with disabilities. It is important that we relay that we oppose the CD Supported Employment service option as proposed in Fast Track Regulations – Waiver Services 12 VAC 30-120.
Wright Choices, Inc. provides employment services to several hundred persons with significant disabilities every year in the Hampton Roads area. We are very supportive of consumer-directed services including Supported Employment (SE) services. However, we are very concerned with how these regulations will effect the integrity and purpose of supported employment services.
Wright Choices, Inc. prides itself on the highly skilled professional employment specialists within our organization. This is not a paraprofessional position, as many others may be in the CD field. Our SE professionals have continuous trainings and requirements to maintain their employment with our organization. This is a highly skilled position and service. It is my understanding that:
·CD Supported Employment (SE) does not fit easily into the usual CD services. We endorse providing maximum flexibility in the regulations, however Supported Employment is a nationally recognized professional service that requires specialized training and experience. It is a service where the professional brings expertise to assist persons with fulfilling their employment potential. This entails a highly skilled professional to ensure success.
·CD Supported Employment provider requirements are wholly inadequate and do not reflect current “best practices” nor does it come close to the requirements Wright Choices, Inc. mandates. CD SE providers should have the same qualifications and requirements as agency directed SE professionals. Basic English, high school diploma and negative TB test, etc. is entirely inadequate.
·Wright Choices' reputation with employers in the community is golden and this reputation is provided by our SE professionals. Watering the qualifications for these professionals would jeopardize our company's reputation. The industry’s reputation is continuously at stake.
·Supported Employment is one of the only waiver services that have a direct service professional title and recognition nationwide. It has a national and state chapter organized professional association – APSE and VA-APSE.
·Our industry in Virginia has an accrediting body, CARF, that provides minimum stardards for providers to adhere to.
In particular, please note the following,
·Page 64 of 161 (6.f)
This item should be deleted. Employees at the SE work site should not be paid to provide consumer-directed supports. This is an industry accepted type of “natural supports.”
·Page 68 of 161
Definition of “Consumer Directed Employee” – Should not be exempt from workers’ compensation. Employers assume that non-staff that work in their offices (whether assisting their employees with disabilities or not) have appropriate insurance coverage including but not limited to liability and/or workman’s comp insurance.
