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:
Additional Service Needs to be Added:
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 email@example.com 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.