Virginia Regulatory Town Hall
Agency
Department for Aging and Rehabilitative Services
 
Board
Department for Aging and Rehabilitative Services
 
Guidance Document Change: Background on the Guidance for the Provision of Community Support Services: The Vocational Rehabilitation (VR) program is the largest program operated by the Department for Aging and Rehabilitative Services (DARS). The agency’s Division of Rehabilitative Services (DRS) is responsible for administering the program, which provides VR services to individuals with disabilities to help them prepare for, secure, regain or retain employment. In some cases, Community Support Services (CSS) are required to establish VR program eligibility, assess rehabilitation and career needs, or achieve an employment outcome. CSS is provided through DARS’ approved employment services organizations (ESO) vendors and may include education, life skills training, and assessment and instruction related to the use of assistive technology. Administration of the VR program and CSS services are directed heavily by federal statutory and regulatory requirements. Background on the Guidance for the Provision of Community Support Services Changes: The 2018 Guidance for the Provision of Community Support Services (CSS) contains outdated information and content that does not provide clear guidance for the appropriate use of CSS. DARS is seeking to delete the current Guidance for the Provision of Community Support Services (CSS) and replace it with a new document, Guidance for the Provision of Vocational Rehabilitation (VR) – Community Support Services (CSS). Listed below is a summary of some of the key changes made to the updated CSS guidance: 1. I. Policy is clarified that CSS services described in the guidance document only apply to the VR program. 2. II. B - Definitions, clarifies DRS staff should save consumer CSS Plans in DocFinity. 3. II. C - Areas to Address by CSS are updated to include communication, interpersonal skills, mobility, self-care, self-direction, work skills, and work tolerance. 4. III Qualified Providers – This section is no longer needed and is deleted. 5. III.B – This applies the DRS informed choice policy to the provision of CSS. 6. IV. The role of the VR counselor is updated to include a more accurate list of services they coordinate with the VR consumer. In addition, the completion of a full CSS assessment can be waived with the approval of a VR supervisor. 7. V. Community Support Assessment/Service Plan is updated to now include Authorization of Referral and to increase the initial authorized amount of time a VR counselor is allotted from eight (8) to ten (10) hours. More than ten (10) hours of service must be approved by a VR supervisor and documented with an Actual Service Note (ASN) and authorization of more than six (6) months of services must be approved by a VR supervisor and documented with an ASN. 8. V. D. The list of CSS Plan elements is updated to match program practices and collect outcomes data. 9. VI. Modifying/Ending Services is updated to include that the CSS Plan may be amended at any time and to clarify reasons CSS may be terminated. 10. VIII. Program Approval is no longer needed and is deleted. 11. VIII. Reimbursement Rates is no longer needed and is deleted. 12. The entire document was reviewed and edited for clarity and compliance with federal and state VR regulations and policies.
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10/18/24  1:48 pm
Commenter: disAbility Law Center of Virginia

dLCV Comment on CSS
 

10/18/24

 

Dear Ms. Arbogast,

 

The disAbility Law Center of Virginia (dLCV) appreciates the opportunity to comment on the Department for Aging and Rehabilitative Services (DARS) policy on the provision of Community Support Services (CSS).  dLCV appreciates that DARS can provide very specific CSS to individuals with disabilities who need the one-on-one services to get, keep or advance in employment.  dLCV further appreciates that DARS recognizes that CSS can come through different service providers and can mean something different to each individual who needs CSS. 

 

That all being said, dLCV recommends that the CSS policy provision update and identify self-advocacy skills training as it relates to the individual’s disability and potential employment as a specific CSS that can be offered.   The proposed policy language does state that life skills training can be a CSS that DARS can provide.  Life Skills training is very broad in nature and does not clearly spell out Self-Advocacy Skills related to one’s disability.  dLCV has seen time and time again where an individual with a disability is afraid to speak to an employer about their disability.  Individuals need to know how to be their own self-advocate as it relates to their disability and their needs for any type of accommodation on the job. dLCV believes if DARS clients have appropriate self-advocacy skills training related to their disability DARS may have a better success rate for potential Vocational Rehabilitation (VR) case closures.

 

Thank you again for the opportunity to comment on the proposed policy revision to CSS.  If you would like to speak with dLCV regarding this comment, please reach out to Robert Gray at robert.gray@dlcv.org.

 

 

 

Sincerely, 

 

Colleen Miller

Executive Director

 

CommentID: 228139