Goodwill of Central Virginia opposes the CD Supported Employment service option as proposed in the Fast Track Regulations - Waiver Services – Section 12 VAC 30-120. While we support consumer-directed supported employment (SE) services, we are not in support of the proposed Fast Track regulations as currently proposed.  CD Supported Employment provider requirements are inadequate and are not reflective of best practices. The current regulations do not require that persons providing supported employment services possess supported employment training or experience.

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 Virginia since the early 1980s. Countless hours have been devoted to perfecting this model and gaining employer acceptance of supported employment as a solution to labor needs. We ask that you review our concerns, consider revising the CD Supported Employment provider requirements and propose requirements that are in line with industry standards

Sharon B. Taylor

Vice President of Education & Training

Goodwill of Central Virginia

Email Address: sbtaylor@goodwillcva.org.