We oppose the CD Supported Employment service option as proposed 12 VAC 30-120.
Eggleston Services is 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 or Supported Employment Specialists (SES)/ Job Coach as a Direct Support Professional.
·CD Supported Employment (SE). Supported Employment is a nationally recognized professional service that requires specialized training and experience and as a result does not fit easily into the usual CD available service menu as CD-Personal Assistance, CD-Companion and CD-Respite services do. It is a service where the professional brings specific expertise to assist the individual in their employment choice to reach their full potential which includes job development, job carving and job training which are very specialized skill sets and differ from the usual skill sets required for a CD assistant.
·CD Supported Employment provider requirements are wholly inadequate and do not reflect current “best practice” in the field 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. are entirely inadequate professional standards.
·Given the challenges in creating community employment outcomes for individuals with significant disabilities, it is critical that a certain level of professionalism and service delivery is the standard to meet the business communities’ specific needs. The professional skills of an Employment Specialist or Job Coach to navigate and integrate themselves into the business community is crucial for the success of SE programs-the minimal professional standards proposed would jeopardize the success of these services by damaging the reputation and level of quality for these services.
·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.
·Through our VA DRS vendor agreement, Eggleston Services is required to be accredited by CARF, an international accrediting body, under the community employment standards to provide supported employment services. These Community Employment Services include Job Development, Job Supports and Job-Site Training as well as the minimum requirements for a Supported Employment Specialist (SES) or Job Coach. Eggleston Services adheres to these professional and industry standards and would encourage it to be used as the basis for all SE service provision in the Commonwealth. Creating two different standards for one service in the commonwealth continues to fragment service delivery
·Waiver participants should expect the same professional Job Coach/Employment Specialist standards as their peers receive through other funding sources as required. Reducing the professional standards creates the perception that waiver services are provided at a reduce quality standard.
We have the following Specific Comment:
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. This is often the first barrier to overcome when negotiating with a business partner.
