2/27/23

Re: dLCV comment on revisions to the WISA Manual

Dear Ms. Arbogast,

The disAbility Law Center of Virginia (dLCV) appreciates the opportunity to comment on the Work Incentive Specialist Advocate (WISA) manual.  dLCV is the protection and advocacy system for the Commonwealth of Virginia. We advocate for all Virginians with disabilities to receive the services and supports that they need to work and have independent lives in the community. 

dLCV recognizes that a WorkWorld analysis is an important tool for individuals who receive Supplemental Security Income (SSI) or Social Security Disability Insurance (SSDI) benefits and want to work. That being said, dLCV recommends that you clarify the WISA manual to state a WorkWorld analysis is not a service that has to happen before the development of the Individualized Plan for Employment (IPE). The WorkWorld Analysis and consult with the WISA are simply services as a part of the IPE and happen in conjunction with other services stated on the IPE. If a WorkWorld Analysis must happen before services in the IPE can continue, this will delay the implementation of the IPE and could negatively affect an individual’s wish to return to work.

Thank you again for the opportunity to comment on the proposed changes to the WISA manual.  Please do not hesitate to contact dLCV if you have further questions. 

Sincerely,

Colleen Miller

Executive Director, dLCV