Virginia Regulatory Town Hall
Agency
Department of Medical Assistance Services
 
Board
Board of Medical Assistance Services
 
chapter
Waivered Services [12 VAC 30 ‑ 120]
Action Mental Retardation/Intellectual Disability Waiver Changes
Stage Proposed
Comment Period Ended on 12/9/2011
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Previous Comment     Next Comment     Back to List of Comments
12/9/11  8:43 pm
Commenter: Sherman Gifford, The Choice Group

Comments on Supported Employment
 

Page 115

SE Services

N. “Intensive” is not the appropriate word to be used here.  Ongoing supports may be intensive or may be periodic depending upon the individual’s circumstances and employer requirements and/or changes.

DELETE “Intensive”.  CHANGE to – “These services shall consist of intensive, ongoing supports that enable individuals…….”

As the overall definition for both individual and group - it should be as flexible as possible to allow fluctuations in service needs.

 

Page 115

SE Services

N.2.a. “Intermittent” is not the appropriate word to be used in regards to individual supported employment.  The definition for “intermittent” in Webster’s is “occurring at irregular intervals”.  We don’t believe this is what should be the definition of “support”. 

 

DELETE “Intermittent”. CHANGE to – “Individual supported employment shall be defined as intermittent support, usually provided……”  We recommend “support” or “ongoing support” which provides flexibility to accommodate individualized support according to the needs of the individual on the job which can change at any time.  Support can continuously change depending upon changing job requirements, site movement, employer needs as well as the individual’s circumstances.  The definition of support can be further defined in the Manual. 

 

Page 115

SE Services

N.2.a. “collateral contacts by providers”

This term/phrase needs to be further defined in the Manual.  Inconsistent interpretations & TA have been provided to providers.

 

Page 115

N.2.b.  “Eight or fewer” is problematic and rigid to some employment circumstances (i.e. grounds maintenance, building maintenance, etc.)

DELETE “eight or fewer” in the regulations. 

CHANGE to - “Group supported employment shall be defined as continuous support provided by staff to eight or fewer individuals with disabilities ……”  Further define in manual to provide flexibility for ever-changing employment opportunities and circumstances as well as staff to client ratios.

 

Page 115

SE Criteria

N.3.a. The wording in this section is problematic and does not allow for maximum flexibility in job development tasks on behalf of an individual.  Regulations should be as broad as possible to allow further definition in Manual to correspond to SE best practices with allowable activities accepted by DRS SE practices and CARF accreditation in SE.

DELETE “specifically include” and “search”.  CHANGE to – “Only job development tasks that specifically include are specific to the individual shall be allowable job development search activities under the ………..”

Job search is only one aspect of job development.

 

Page 115

SE Service Units and Definitions

N.4.c.  The regulations specifically mention compensation for “group models of SE” and the DMAS fee schedule.  However, no mention of Individual SE hourly rates based upon provider specific rates authorized by DRS.

ADD – Individual SE rate statement

Individual supported employment rates are provider specific based on rates authorized by the Department of Rehabilitative Services (DRS)’)

This statement is already used on the DMAS rate schedule and differentiates between the Group and Individual SE services.  

 

Page 115

SE Service Units and Definitions

N.4.d. Should be “minutes” versus “seconds”.

Should be “a period of time from one hour through three hours and 59 seconds minutes.”

CommentID: 21222