Public Comment on High Needs Support Benefit Delivery System Design

From:  Karen Tefelski, Executive Director, Virginia Association of Community Rehabilitation Programs Dba vaACCSES

We have reviewed the Operational Design and Implementation Planning paper and have the following preliminary comments.  We look forward to working with DMAS as they move forward with designing this program.

Further clarification needed:

• Is the program time limited? 
• What is the process in determining which individuals receive slots?
• Specific eligibility for the program is not clear.  Does it include DD Waiver participants in CCC+?
• States that individuals on the DD Waiver waitlist are eligible for the HNS program.  What impact will that have on the individual’s waitlist status (i.e. Priority1 status)?
• What is meant by “expected to benefit from supports” eligibility criteria?
• Interaction with DARS and an ESO and the program referral process, service process and follow along process and funding need to be further clarified.  How do ESOs get referrals?  How do individuals have true “choice” for employment and/or housing providers?

Additional Service Needs to be Added:

• Benefits Assistance and Work Incentives Counseling Services need to be added if employment services are provided under this program.  Historically, individuals are afraid to work for fear of losing medical and housing benefits.  Counseling on both federal and state work incentives as well as the impact of work on SSA benefits and housing benefits is critical.  Benefits planning queries (BPQY) need to be obtained from SSA to verify benefits and work history.  Individuals need to be informed regarding the impact of work on benefits and what work incentives are available to help them maintain employment. There is no way of knowing an individual’s entitlement continuum and work history without this information.  Social Security Administration certified Work Incentives & Planning Assistance (WIPA) Community Work Incentives Counselors (CWIC) and DARS certified Work Incentive Specialist Advocates (WISA) should be added as qualified providers of this service.  SSA CWICs hold a level 5 federal security clearance and are required to have 18 hours of specialized training each year to hold their certification.   See DD Waiver Benefits Planning and Assistance Counseling service.

Employment Provider Rates - Individual Competitive Supported Employment (ISE) rates in Virginia have been established by the General Assembly to be the ISE rates established by the Virginia Department for Aging and Rehabilitative Services (DARS).  Virginia procurement law states that an identical service provided to different state agencies must be provided at the same rate.  The paper talks about establishing rates and further states that the MCOs would be able to negotiate rates with providers.  This would not be allowable under current procurement law.

Please do not hesitate to contact me at ktefelski@vaaccses.org or 703-200-7660.  We welcome active involvement in the development of this program.  Non state agency stakeholders need to be more actively involved in the development of this program.

VaACCSES is a statewide association of quality community-based providers supporting individuals with  DD/ID, autism, mental illness, substance use disorders, physical disabilities, blind and visually impaired, deaf and hard of hearing and other disabilities.  Our members are CARF accredited and provide all types of residential services, group day services, Community Engagement, Community Coaching, In-Home Support Services, Respite, Benefits Counseling and Employment.   The association started as an organization of employment providers in the mid-1970s.  Although we represent a multitude of other providers, we are considered the primary advocacy organization representing employment providers and promoting employment policy for Virginians with disabilities in Virginia.