2/28/25

Re: dLCV comment on DARS policy manual

Dear Ms. Arbogast,

The disAbility Law Center of Virginia (dLCV) appreciates the opportunity to comment on the Department for Aging and Rehabilitative Services (DARS) revisions to the Vocational Rehabilitation (VR) policy manual.  dLCV appreciates DARS continuing to maintain your policy manual in line with Federal regulations and Virginia Code.

dLCV recommends the following: 

1. In the financial participation section, you explain how the individual getting VR services and family, if applicable, shall participate in the cost of services.  You state what factors are applied in your consideration for providing the service.  You state that comparable benefits are considered.  This would be a good place to define what comparable benefits are.  dLCV realizes that you have an entire chapter on comparable benefits, but giving a succinct definition at this place would be very helpful to those reading the manual.  
2. In chapter 5, your current language explains that the employment goal on the Individualized Plan for Employment (IPE) will be considered “to the extent” of the strengths and weaknesses.  dLCV recommends the following change:  The job goal is consistent with the unique strengths, resources, priorities, concerns, abilities, and capabilities of the individual based on the results of the eligibility determination assessment and any additional needs assessments needed to develop the Employment Plan. dLCV recommends that you remove “to the extent”. 
3. In your Guidance 2, you state the “job market” is a part of your consideration when agreeing to the mutually agreed upon goal.  dLCV recommends that you have a more in-depth explanation here to explain how you use the job market in consideration of agreeing to an employment goal. Many individuals especially the younger students do not understand the considerations to the job market.  Often times individuals believe if they want a goal that it should be approved.  They do not consider that their particular job interest may not be a very marketable option for employment.    
4. In the revisions on financial participation of post-secondary education where you have language about the RS-25, dLCV recommends that you add language that the VR Counselor will meet with client each semester to consider if part-time classes need to be considered for the coming semester.  A client’s needs with his or her disability can change in a semester and part-time classes can happen and the individual should not have to put education on hold just because the RS-25 supported full-time classes when it was first completed. 
5. In chapter 14, where the revisions state that if a client is served by both DARS and DBVI the agency will use their own policy to consider financial participation, dLCV recommends that you clearly state that DARS will collaborate with DBVI to ensure that the client gets the most appropriate services. 

In conclusion, once DARS policy staff are ready to publish the revisions to the manual, dLCV recommends that you place the updated manual in a very prominent location on your website.  The VR policy manual is not easy to find on the website.  This is a public document so it needs to be easily accessible to the public.  Finally, DARS Policy Staff need to hold a mandatory training for all VR Counselors, Office Managers and District Directors to explain the revisions to the manual and how to apply the revisions in everyday best practice.  dLCV often finds DARS staff differ in their understanding of policies and how they are applied. 

Thank you again for the opportunity to comment on the revisions to the VR policy manual.  If you have questions, please do not hesitate to reach out to me at robert.gray@dlcv.org.

Sincerely,

Robert Gray

Director for Compliance and Quality Assurance

dLCV