March 25, 2008

Brian McCormick, Regulatory Supervisor

Department of Medical Assistance Services

600 E. Broad Street, Suite 1300

Richmond, VA  23219

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 Megan Bergen, Director- Mission Services at 540 371 3070 or megan.bergen@fredgoodwill.org.

Sincerely,

C. W. Van Valkenburgh

President/CEO

cc: vaACCSES