Support the allowance of employment services organizations (ESOs) to be providers of Peer Mentor Supports, Employment & Community Transportation Services and Community Guide services.

Support the consistent use of “progress notes” as defined in the DD Waiver regulations versus the use of “daily note” references. We support the definition of “progress notes” as defined in 12VAC30-122-20 “Definitions” for consistency. “Progress notes” means individual-specific written documentation that (i) contains unique differences specific to the individual’s circumstances and the supports provided, and the individual’s responses to such supports; (ii) is signed and dated by the person who rendered the supports; and (iii) is written and signed and dated as soon as is practicable but no longer than one week after the referenced service.”

A.10.d- Strike “Such documentation shall be written on the date of service delivery.” This is not in keeping with the definition of Progress Note in 122-20 and as referenced earlier in comments.

Support changing the 10-day requirement to a 15-day requirement for service providers to submit quarterly reports.

C. (3) - Group and individual supported employment service shall take place in nonresidential settings separate from the individual's home.  Recommendation: Change wording to allow for services, which may occur in an individual's home, such as job development or for individuals that work or telework from their home.

C.4. – Strike “service” after employment. Strike “in combination with other day service or residential service” and Change to “concurrently with other waiver services for purposes of job discovery”. Should read as follows: “For time limited and service authorized periods (not to exceed 24 hours) individual supported employment service may be provided in combination with concurrently with other waiver services for purposes of job discovery.”

E.1.c. – Sentence needs to be reworked. “Documentation confirming the individual’s time in service” is for Group Supported Employment (GSE) only. “Daily note” is only applicable to GSE as well. Strike “daily note” and insert “progress note” to be consistent with other sections and definition of “progress note” in Section 122-20.

E.1.f. - Sentence needs to be reworked. Should read “Documentation that indicates the date, type of service rendered, and the number of hours provided, including specific timeframe. An attendance log or similar document shall be maintained for Group Supported Employment”. An attendance log or similar document is not required for ISE since the individual is competitively employed.

E.1.i. – After group, Insert “for Group Supported Employment”.