March 28, 2008

Brian McCormick

Regulatory Supervisor

Department of Medical Assistance Services

600 East Broad Street, Suite 1300

Richmond, VA  23219

Dear Mr. McCormick:

I am strongly opposed to the proposed Waivered Services [12 VAC 30 - 120] for a multitude of reasons.  Most importantly, I am sincerely concerned that the proposed regulations will have a detrimental effect on individuals with disabilities who are seeking to obtain and maintain employment in the community.  Those providing direct service in the field of supported employment are professionals and they have specific qualifications and experience that are critically essential to the provision of quality services.

In the Commonwealth of Virginia, organizations that provide supported employment services through the Department of Rehabilitation Services are required to maintain accreditation with CARF - the Commission on Accreditation of Rehabilitation Facilities.  One of the cornerstones of CARF accreditation is outcomes measurement. Accordingly, CARF-accredited programs continually seek to measure and to enhance the quality and effectiveness of their supported employment services.

Consumer choice is at the center of all CARF accredited services.  While supported employment services are tailored to the individual needs of each consumer and the requirements of the employer, supported employment professionals have experience working with other consumers and they utilize best practices in the field.  The relationships and partnerships that they have been developed with employers are frequently critical to success of consumers.

Beyond the accreditation requirements, most individuals who are actively engaged in supported employment have specific training and experience in working with people with disabilities and in job placement activities.  Many pursue specialized training in supported employment through courses, seminars and workshops.  Additional educational and networking opportunities are available through vaACCSES - the Virginia Association of Community Rehabilitation Programs, the Virginia Association of Persons in Supported Employment and the Virginia Rehabilitation Association.

WorkSource serves approximately 450 citizens with disabilities from the City of Charlottesville and Albemarle, Fluvanna, Greene, Louisa and Nelson counties.  With the assistance of WorkSource employment specialists, 320 consumers worked at 88 different during the year ended June 30, 2007.

As the current President of vaACCSES, I am also very familiar with the great work done by other supported employment vendors throughout the Commonwealth.  Individuals with disabilities deserve the right to chose providers of supported employment services who are knowledgeable, experienced and qualified.  Unfortunately, that cannot be assured with the proposed regulations.

Sincerely,

Charles J. McElroy

President & CEO

cc: Karen Tefelski

Executive Director

vaACCSES