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 Virginia, is serving a population considered to be the "most severe".  This population of individuals requires the highest quality of services available from the most qualified service practitioner.  In our agency, this often means a person with a Master's degree in Rehabilitation Counseling or Special Education, or a Bachelor's level education with relevant experience working with individuals with disabilities.  This is our minimum, and from my experience, this level of education, training, and experience is necessary for one to fully understand the needs of the persons we serve, assess their strengths and barriers to employment and independence, develop a professional plan for services, implement strategies to overcome barriers with measurable outcomes, and to be able to provide quality consumer-directed and person-centered services.  Due to the nature of the work involved and knowledge and experience needed for this occupation, Supported Employment Specialists should never be confused as being at the entry level of the field, even though this position is often and incorrectly categorized as just that.

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 Commonwealth of Virginia.  The expectation for service providers to meet a standard of measure should be consistent for all agencies (State and Federal); and, this should be the expectation that DMAS has for all services providers interested in providing Supported Employment – Waiver services.

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,

Sharon Barton, MS, CRC, CRP

Manager of Supported Employment Services

RSVP, Inc.