We are writing to state our objection to the Proposed Waiver Services Section 12 VAC 30-120

VA-APSE is a statewide association engaged in the business of advocacy and education to improve and expand integrated employment opportunities for Virginians with severe disabilities. We are a chapter of the National Association of Persons in Supported Employment. Our Board of Directors voted at its recent meeting to oppose the Fast Track Regulations for the MFP Demonstration project.  Knowing the importance of this demonstration project to people with severe disabilities across the Commonwealth, we take this action with much consideration.  We hope that DMAS will halt the Fast Track process and proceed instead with Emergency Regulations, thus allowing the demonstration project to begin as now planned on July 1, 2008.

VA-APSE is very supportive of consumer-directed services, including Supported Employment services.  Our greatest concern is with the definition of “Employment Assistant” under the proposed regulations for Consumer-directed services - Supported Employment option.  This classification of worker, with its minimum level of requirements and no required supported employment training, will have a negative impact on both the quality of services to waiver consumers as well as to the profession of Supported Employment.  Regulations for Consumer-directed services should parallel the requirements for Agency-directed services.

Supported Employment Specialists /aka Job Coach is not a paraprofessional position as with some other consumer-directed services.  A large percentage of Job Coaches in Virginia are Masters level professionals.  Supported Employment is a nationally accredited CARF service titled Community Employment Services that includes Job Supports, Job Development, and Job-Site Training.  CARF defines the minimum requirements for a Supported Employment Specialist / Job Coach.

Further, in Virginia, the Department of Rehabilitative Services requires that all of its vendors of Community Employment Services – Supported Employment – meet these CARF requirements.  We ask that the MFP regulations include these same standards of training and excellence.  VA-APSE supports training for job coaches to earn a National Certificate in Employment Services as approved by the Association of Community Rehabilitation Educators.  We are not asking that this certification be a requirement in the MFP regulations.  We only mention this to emphasize the fact that Supported Employment services are designed to respond to the employment needs of people with the most severe disabilities, and as such, require skilled professionals who are knowledgeable of the needs of people with disabilities, the employment market and the business sector.

We ask again that you halt the Fast Track process and work with organizations such as VA-APSE and vendors of Supported Employment to design regulations that more accurately reflect the standards and best practices of Supported Employment in Virginia.  Thank you for your consideration.

Sincerely,

Joanne Packert, President

Virginia Association of Persons in Supported Employment

J_Packert904@msn.com