What I repeatedly see is policy that allows extreme profiting from disability and inequitable delivery and utilization of Home and Community Based Services.

There is a genocide being covered up in America. People with disabilities are being murdered in group homes. Case in point, private group homes owned by KKR are under investigation currently. I'm waiting to see who will get convicted of murder with a life sentence in prison.

What I've experienced/seen:
1.
Myself and others can not find Medicaid Consumer (self) Directed personal care in home attendants because they are not paid anything close to a living wage. A fast food job pays more than a in home Consumer Directed attendant.

2.
Private companies can buy group homes and rack in extreme profit off beds while people with disabilities are abused neglected and murdered. Group homes are allowed to pay more to their attendants than Consumer Directed. Remove penalties for supplementing a CD attendants pay so I can compete with fast food and group homes.

3.
Agencies can start an attendant business anywhere and have lack regulations. Because of agency's unprofessionalism and unethical behavior, their attendant turnover rate is extremely high. The agency is paid when their attendants do not come into work, which is Medicaid fraud. These agencies are numerous which deplete my hiring pool. Shut down agencies and bring back tools to empower people on Consumer Directed such as MySupport.

4.
There is no equity in data. Data collection focuses on Providers and not Consumers. On a similar note, the US Census does not collect any data specifically related to HCBS providers or consumers. Require survey and feedback opportunities be given to Consumers.

Redirect funds to pay a living wage to Consumer Directed personal care in home attendants from these sources:
1.
Agency office getting paid when attendant doesn’t come in to work
2.
Transportation brokers getting paid for each person on Medicaid regardless if that person uses transportation or not (company hub in Georgia}
3.
DOJ annual reviews of Virginia settlement agreement (how many reviews have there been? repeated reviews cost money)
4.
Eliminate evaluations to use AT funding on the DD Waiver. To qualify for the DD Waiver I had OT assessments and evaluations These repeated tests are an example of extreme profiling off disability services
5.
Due to ableism, I hear the excuse of the "fax is lost". I have heard it so many times from various entities, over so many years that I get another provider involved which essentially ends with charging insurance twice.

Require hourly pay rates be on a public webpage for attendants working as Consumer Directed, in home agency and group home.

My husband can not return to work with the current state of in home attendants.
I once worked from home and was paid a full wage. One of the factors of why I resigned was the current state of in home attendants.

I'm on a conveyor belt of a broken system with no choice but a group home to be a paycheck in somebody's pocket.

Close the gab between minimum wage and living wage rates for Consumer Directed Medicaid in home Personal Care Attendants. In Virginia the gap is $7.

End Institutional bias in policy.

How much is Virginia's GDP tied to extreme profiting off disability services? What incentive do policy/law makers have to change policy so there's equity in pay of these three care settings? Group, agency, and Consumer Directed?

We always get conflicting information from DMAS and DBHDS. There needs to be the same language from both organizations. Attendants working through Consumer Direct should not be required to have the background form notarized. This is a thing of the past. There needs to be a straight forward way to outline the roles of Service Coordinators and Service Facilitators.

Please add clarification under Service Definition/Description for who is a Behavior Consultant. I suggest you list the titles, such as LBA/BCBA, PBSF, LCSW, LPC, etc.  Are BCaBA's behavior consultants, if so then please add them to the list. In the same section - please define physical therapy disciplines - is this only licensed physical therapist or does this include PTA, COTA, or who?

Please change pronouns to he/she/they.

Under Service Documentation Requirements (pg. 153) For behavioral consultation, the annual review must include graphed or tabled data that is trended across the first three quarters; Behavior consultation is only approved for 180 days = 6 months. I am not sure how we are to trend data for 9 months with an approval of 6 months. 

In the same section, A contemporaneously signed and data final disposition summary that is forward to the support coordinator within 30 days following the end of this service and that includes: Providers do not have access to WaMS to enter final disposition after the end date of service. This makes it impossible to forward the final disposition 30 days after services are termed. I suggest we follow the previous regulations and do 30 days prior or after.

All therapists should be listed under code 97139. 

Nursing consultation should be added as a service option.

When the Therapeutic Consultation regulations were updated in 2021, this should’ve been reflected in the billable rates. All Behaviorist, regardless of credentials, are required to follow the same guidelines for this service, yet are not able to bill equally. 

I feel that clarification is needed under Service Definition/Description for who is a Behavior Consultant. I think that it is pertinent that you list titles such as LBA/BCBA, PBSF, LCSW, LPC, etc.   

I feel that Nursing consultation should be added as a service option. It can often be beneficial to have a nursing consult to discuss unfamiliar or complicated diagnoses, medications, and medical concerns that may need to have additional medical follow up by specialists that may not have been previously considered by the overwhelmed and reducing number of medical doctors who provide services for the ID/ DD population. 

Under Service Documentation Requirements (pg. 153) For behavioral consultation, the annual review must include graphed or tabled data that is trended across the first three quarters; Behavior consultation is only approved for 180 days = 6 months therefore unless service authorizations are going to be approved for longer periods of time, I am not sure how we are going to be held accountable to trend data for 9 months with an approval of only 6 months. 

In the same section, A contemporaneously signed and data final disposition summary that is forward to the support coordinator within 30 days following the end of this service and that includes: Providers do not have access to WaMS after the end date of the service authorization. This makes it impossible to forward the final disposition 30 days after services are terminated. I would suggest to continue following the previous regulations and do 30 days prior or after.

Lastly, believe that All therapists should be listed under code 97139, instead of Occupation Therapy, Speech Therapy, and BCBA being listed at 97139 and LBA/BCBA, PBSF, LCSW, LPC, Psych, and Recreation Therapy listed under 97530. I think it would be only right that all Therapeutic Consultation services should reimbursed at the same rate of pay. BCBA's, LBA/BCBA, PBSF, LCSW, LPC 's all provide Behavior Consultation services. We are all held to the same standards and expectations, so it does not seem justified that BCBA's would fall under a different code (and a higher reimbursement rate) than those who are not BCBA's. Recreation Consultants also provide a very valuable service to the individuals and supporters we serve. The services they provide often work in conjunction with other therapeutic disciplines and they deserve to be classified and viewed with the same type of professional respect. 

By sliding AT for the under 21 group, under EPSDT, the criteria is a barrier to access to this group in getting AT items to increase ability to control environment, support ISP outcomes as identified, and live safely and independently in the least restrictive community setting.

Due to fact that EPSDT criteria is more restrictive than the AT criteria that those 21 and over have.

EPSDT criteria must be for the treatment of the individual's disability or to improve a physical or mental condition;

Example: Assistive devices; GPS tracking for wandering and elopement. 

We, the Public Policy Committee of the Virginia Association for Behavior Analysis, have the following comments on the Draft Development Disabilities Waivers Chapters II, IV, and Appendix D.  We thank you for the opportunity and partnership.  Many of our members are providers of Therapeutic Consultation as Licensed Behavior Analysts and Licensed Assistant Behavior Analysts.

On page 37 of Appendix D, the unit of service is listed as 1 hour.  However, a 15 minute-unit would be more efficient and less open to waste.  Frequently, providers of therapeutic consultation provide services over or under the hour mark and then must adjust for billing purposes.  Often this results in the provider not being paid for services provided under 30 minutes or the provider being paid for services not provided but rounded up to the next hour.  15-minute units are common for many of the providers who deliver these services.

Currently, Therapeutic Consultation services are only provided to those with the Family and Individual Supports Waiver or Community Living Waiver.  These services would be very beneficial for individuals with the Building Independence Waiver as well, especially in helping them to remain on that waiver and not need more intensive care.

We thank you for the opportunity to comment and welcome your continued partnership.

The DD system is in need of improvements. This is a start. 

There is a discrepancy in the manual regarding the number of hours a Consumer Directed attendant can work.

Pages 190, 193, and 203 of Chapter IV incorrectly state that attendants are limited to 40 hours per week for each EOR.

Pages 11, 26, and 31 of Appendix D correctly state that each attendant is limited to 56 hours per week for each EOR.

On page 22 and 23 there are links to resources, documents (DSP Competency Required Documents with incorrect and duplicative form numbers), and the VA Code that have inaccurate documents posted or do not take you to a valid webpage.  Please review for accuracy.

We believe that the CMS fingerprinting requirements will present significant challenges to organizations that provide DD Waiver services.

As an ESO with more than 60 Job Coaches who might have occasion to provide DD Waiver supports, this regulation will present a substantial administrative burden to our organization and to our staff.

We currently perform annual background checks on more than 70 employees and the fingerprinting requirement seems excessive and unnecessary.

Additionally, we believe that this requirement could very well have a negative impact on our ability to recruit new staff members, and like most providers we are already struggling to recruit and retain DSP’s / Job Coaches.    And recruitment of new staff directly correlates with our service capacity, thus resulting in fewer services being delivered to an already underserved population of people with significant disabilities.  

DD Waiver Manual – Chap 2 and Chap 4

OVERALL COMMENTS:

1. Appreciate the addition to Respite to not require the submission of a quarterly report when respite is not provided to the individual during the quarter.
2. Consistency between DD Waiver Regs/Manual and Licensing Regs regarding submission of Quarterly Report to Support Coordinator for all services.

For Example:  Ch. IV, p.212 - Respite: 

· The content of each review must be discussed with the individual and family member/caregiver, as applicable and submitted to the Support Coordinator within 10 calendar days following the end of each ISP plan quarter. . .

The requirement should be changed to match up with the licensing regulations found below in 12VAC35-105-675.D.3 which states:

For goals and objectives that were not accomplished by the identified target date, the provider and any appropriate treatment team members shall meet to review the reasons for lack of progress and provide the individual an opportunity to make an informed choice of how to proceed. Documentation of the quarterly review shall be added to the individual's record no later than 15 calendar days from the date the review was due to be completed, with the exception of case management services. Case management quarterly reviews shall be added to the individual's record no later than 30 calendar days from the date the review was due.

3. Barrier to AT Access for children under 21.  By putting AT under the 21 year old age group under EPSDT, the criteria is a barrier to access for this group in getting AT items to “increase ability to control environment, support ISP outcomes as identified, and live safely and independently in the least restrictive community setting”. The EPSDT criteria is more restrictive than the Waiver AT criteria for those under 21 versus those over 21 under the Waiver. EPSDT criteria must be for the treatment of the individual’s disability or to improve a physical or mental condition”. We understand that EPSDT has to be the first priority for authorization and payment.  Recommendation: If an individual under 21 that has a waiver slot and does not meet the EPSDT requirements, they should be automatically referred to eligibility standards under the DD waiver.  Those that have a waiver slot should have access to the same standards and services whether they are under 21 or over 21. 

CHAPTER 2

Page 22 - the link takes you to VCU website but says the page is not active and the link as noted below on page 23 goes to the VA Code. Still has incorrect form numbers. For example, the DSP Basic competency and health competency have the same form number.  This has never been updated. 

Previous Comment submitted during last review (Nov 2021). A signed assurance document confirms the receipt of instruction in the required training topics. Assurance documents are specific to DSP/DSP Supervisor role. There are two versions and DSPs and DSP supervisors complete the version that matches their role within the organization. These assurance documents are available online at: https://law.lis.virginia.gov/admincode/title12/agency30/chapter122/section9998/

These forms at this link had incorrect form numbers, etc. A vaACCSES member previously let Jason Perkins and Eric Williams know this back in 2021 and this still has not been fixed.

CHAPTER 4

Page 126:

We understand that this section is included to be consistent with DARS.

Here is our recommendation for edits to improve language:

When the individual has demonstrated a period of stability in employment independent of service intervention the individual supports may move to a follow-along status. Stability in employment is determined by the following criteria:

· Intervention has reached a "plateau" or leveled out;

· Individual demonstrates appropriate work behaviors and social skills on the job;

· Individual can perform expected job duties;

· Individual is satisfied with the job and work environment;

· Supervisor is satisfied with the individual’s job performance;

· Necessary worksite modifications and accommodations are in place;

· Transportation to and from work is reliable; and

· Compensation is at or above minimum wage and not less than wages paid by employer for same work performed by people without disabilities.

Follow-Along is defined as those on-going supports necessary to assist an individual with a developmental disability to sustain maintain competitive work in an integrated setting of their choice. Upon reaching stability and follow along, the support team and the individual should discuss whether:

Page 127:
Here’s our recommendations for edits:

·  Vocational or job-related discovery (we are recommending to take this out as its confusing and is covered in the CE section) or assessment such as a situational assessment – when the individual completes attempts work tasks in one or more competitive employment environments in the community. The purpose of the SA is to assist individual in determining vocational options, direction, goals and training strategies.

CHAPTER 2

Page 22 - the link takes you to VCU website but says the page is not active and the link as noted below on page 23 goes to the VA Code. Still has incorrect form numbers. For example, the DSP Basic competency and health competency have the same form number.  This has never been updated.  

Previous Comment submitted during last review (Nov 2021). A signed assurance document confirms the receipt of instruction in the required training topics. Assurance documents are specific to DSP/DSP Supervisor role. There are two versions and DSPs and DSP supervisors complete the version that matches their role within the organization. These assurance documents are available online at: https://law.lis.virginia.gov/admincode/title12/agency30/chapter122/section9998/

These forms at this link had incorrect form numbers, etc. A vaACCSES member previously let Jason Perkins and Eric Williams know this back in 2021 and this still has not been fixed. 

CHAPTER 4

Page 126: 

We understand that this section is included to be consistent with DARS.

Here is our recommendation for edits to improve language:

When the individual has demonstrated a period of stability in employment independent of service intervention the individual supports may move to a follow-along status. Stability in employment is determined by the following criteria:

· Intervention has reached a "plateau" or leveled out;

· Individual demonstrates appropriate work behaviors and social skills on the job;

· Individual can perform expected job duties;

· Individual is satisfied with the job and work environment;

· Supervisor is satisfied with the individual’s job performance;

· Necessary worksite modifications and accommodations are in place;

· Transportation to and from work is reliable; and

· Compensation is at or above minimum wage and not less than wages paid by employer for same work performed by people without disabilities.

Follow-Along is defined as those on-going supports necessary to assist an individual with a developmental disability to sustain maintain competitive work in an integrated setting of their choice. Upon reaching stability and follow along, the support team and the individual should discuss whether:

Page 127: 
Here’s our recommendation 

·  Vocational or job-related discovery (we are recommending to take this out as its confusing and is covered in the CE section) or assessment such as a situational assessment – when the individual completes attempts work tasks in one or more competitive employment environments in the community. The purpose of the SA is to assist individual in determining vocational options, direction, goals and training strategies.

OVERALL COMMENTS:

1. Appreciate the addition to Respite to not require the submission of a quarterly report when respite is not provided to the individual during the quarter.
2. Consistency between DD Waiver Regs/Manual and Licensing Regs regarding submission of Quarterly Report to Support Coordinator for all services.

For Example:  Ch. IV, p.212 - Respite: 

· The content of each review must be discussed with the individual and family member/caregiver, as applicable and submitted to the Support Coordinator within 10 calendar days following the end of each ISP plan quarter. . .

The requirement should be changed to match up with the licensing regulations found below in 12VAC35-105-675.D.3 which states:

For goals and objectives that were not accomplished by the identified target date, the provider and any appropriate treatment team members shall meet to review the reasons for lack of progress and provide the individual an opportunity to make an informed choice of how to proceed. Documentation of the quarterly review shall be added to the individual's record no later than 15 calendar days from the date the review was due to be completed, with the exception of case management services. Case management quarterly reviews shall be added to the individual's record no later than 30 calendar days from the date the review was due.

3. Barrier to AT Access for children under 21.  By putting AT under the 21 year old age group under EPSDT, the criteria is a barrier to access for this group in getting AT items to “increase ability to control environment, support ISP outcomes as identified, and live safely and independently in the least restrictive community setting”. The EPSDT criteria is more restrictive than the Waiver AT criteria for those under 21 versus those over 21 under the Waiver. EPSDT criteria must be for the treatment of the individual’s disability or to improve a physical or mental condition”. We understand that EPSDT has to be the first priority for authorization and payment.  Recommendation: If an individual under 21 that has a waiver slot and does not meet the EPSDT requirements, they should be automatically referred to eligibility standards under the DD waiver.  Those that have a waiver slot should have access to the same standards and services whether they are under 21 or over 21. 

CHAPTER 2

Page 22 - the link takes you to VCU website but says the page is not active and the link as noted below on page 23 goes to the VA Code. Still has incorrect form numbers. For example, the DSP Basic competency and health competency have the same form number.  This has never been updated. 

Previous Comment submitted during last review (Nov 2021). A signed assurance document confirms the receipt of instruction in the required training topics. Assurance documents are specific to DSP/DSP Supervisor role. There are two versions and DSPs and DSP supervisors complete the version that matches their role within the organization. These assurance documents are available online at: https://law.lis.virginia.gov/admincode/title12/agency30/chapter122/section9998/

These forms at this link had incorrect form numbers, etc. A vaACCSES member previously let Jason Perkins and Eric Williams know this back in 2021 and this still has not been fixed.

CHAPTER 4

Page 126:

We understand that this section is included to be consistent with DARS.

Here is our recommendation for edits to improve language:

When the individual has demonstrated a period of stability in employment independent of service intervention the individual supports may move to a follow-along status. Stability in employment is determined by the following criteria:

· Intervention has reached a "plateau" or leveled out;

· Individual demonstrates appropriate work behaviors and social skills on the job;

· Individual can perform expected job duties;

· Individual is satisfied with the job and work environment;

· Supervisor is satisfied with the individual’s job performance;

· Necessary worksite modifications and accommodations are in place;

· Transportation to and from work is reliable; and

· Compensation is at or above minimum wage and not less than wages paid by employer for same work performed by people without disabilities.

Follow-Along is defined as those on-going supports necessary to assist an individual with a developmental disability to sustain maintain competitive work in an integrated setting of their choice. Upon reaching stability and follow along, the support team and the individual should discuss whether:

Page 127:
Here’s our recommendations for edits:

·  Vocational or job-related discovery (we are recommending to take this out as its confusing and is covered in the CE section) or assessment such as a situational assessment – when the individual completes attempts work tasks in one or more competitive employment environments in the community. The purpose of the SA is to assist individual in determining vocational options, direction, goals and training strategies.

OVERALL COMMENTS:

1. Appreciate the addition to Respite to not require the submission of a quarterly report when respite is not provided to the individual during the quarter.
2. Consistency between DD Waiver Regs/Manual and Licensing Regs regarding submission of Quarterly Report to Support Coordinator for all services.

For Example:  Ch. IV, p.212 - Respite: 

· The content of each review must be discussed with the individual and family member/caregiver, as applicable and submitted to the Support Coordinator within 10 calendar days following the end of each ISP plan quarter. . .

The requirement should be changed to match up with the licensing regulations found below in 12VAC35-105-675.D.3 which states:

For goals and objectives that were not accomplished by the identified target date, the provider and any appropriate treatment team members shall meet to review the reasons for lack of progress and provide the individual an opportunity to make an informed choice of how to proceed. Documentation of the quarterly review shall be added to the individual's record no later than 15 calendar days from the date the review was due to be completed, with the exception of case management services. Case management quarterly reviews shall be added to the individual's record no later than 30 calendar days from the date the review was due.

3. Barrier to AT Access for children under 21.  By putting AT under the 21 year old age group under EPSDT, the criteria is a barrier to access for this group in getting AT items to “increase ability to control environment, support ISP outcomes as identified, and live safely and independently in the least restrictive community setting”. The EPSDT criteria is more restrictive than the Waiver AT criteria for those under 21 versus those over 21 under the Waiver. EPSDT criteria must be for the treatment of the individual’s disability or to improve a physical or mental condition”. We understand that EPSDT has to be the first priority for authorization and payment.  Recommendation: If an individual under 21 that has a waiver slot and does not meet the EPSDT requirements, they should be automatically referred to eligibility standards under the DD waiver.  Those that have a waiver slot should have access to the same standards and services whether they are under 21 or over 21. 

CHAPTER 2

Page 22 - the link takes you to VCU website but says the page is not active and the link as noted below on page 23 goes to the VA Code. Still has incorrect form numbers. For example, the DSP Basic competency and health competency have the same form number.  This has never been updated. 

Previous Comment submitted during last review (Nov 2021). A signed assurance document confirms the receipt of instruction in the required training topics. Assurance documents are specific to DSP/DSP Supervisor role. There are two versions and DSPs and DSP supervisors complete the version that matches their role within the organization. These assurance documents are available online at: https://law.lis.virginia.gov/admincode/title12/agency30/chapter122/section9998/

These forms at this link had incorrect form numbers, etc. A vaACCSES member previously let Jason Perkins and Eric Williams know this back in 2021 and this still has not been fixed.

CHAPTER 4

Page 126:

We understand that this section is included to be consistent with DARS.

Here is our recommendation for edits to improve language:

When the individual has demonstrated a period of stability in employment independent of service intervention the individual supports may move to a follow-along status. Stability in employment is determined by the following criteria:

· Intervention has reached a "plateau" or leveled out;

· Individual demonstrates appropriate work behaviors and social skills on the job;

· Individual can perform expected job duties;

· Individual is satisfied with the job and work environment;

· Supervisor is satisfied with the individual’s job performance;

· Necessary worksite modifications and accommodations are in place;

· Transportation to and from work is reliable; and

· Compensation is at or above minimum wage and not less than wages paid by employer for same work performed by people without disabilities.

Follow-Along is defined as those on-going supports necessary to assist an individual with a developmental disability to sustain maintain competitive work in an integrated setting of their choice. Upon reaching stability and follow along, the support team and the individual should discuss whether:

Page 127:
Here’s our recommendations for edits:

·  Vocational or job-related discovery (we are recommending to take this out as its confusing and is covered in the CE section) or assessment such as a situational assessment – when the individual completes attempts work tasks in one or more competitive employment environments in the community. The purpose of the SA is to assist individual in determining vocational options, direction, goals and training strategies.

OVERALL COMMENTS:

1. Appreciate the addition to Respite to not require the submission of a quarterly report when respite is not provided to the individual during the quarter.
2. Consistency between DD Waiver Regs/Manual and Licensing Regs regarding submission of Quarterly Report to Support Coordinator for all services.

For Example:  Ch. IV, p.212 - Respite: 

· The content of each review must be discussed with the individual and family member/caregiver, as applicable and submitted to the Support Coordinator within 10 calendar days following the end of each ISP plan quarter. . .

The requirement should be changed to match up with the licensing regulations found below in 12VAC35-105-675.D.3 which states:

For goals and objectives that were not accomplished by the identified target date, the provider and any appropriate treatment team members shall meet to review the reasons for lack of progress and provide the individual an opportunity to make an informed choice of how to proceed. Documentation of the quarterly review shall be added to the individual's record no later than 15 calendar days from the date the review was due to be completed, with the exception of case management services. Case management quarterly reviews shall be added to the individual's record no later than 30 calendar days from the date the review was due.

3. Barrier to AT Access for children under 21.  By putting AT under the 21 year old age group under EPSDT, the criteria is a barrier to access for this group in getting AT items to “increase ability to control environment, support ISP outcomes as identified, and live safely and independently in the least restrictive community setting”. The EPSDT criteria is more restrictive than the Waiver AT criteria for those under 21 versus those over 21 under the Waiver. EPSDT criteria must be for the treatment of the individual’s disability or to improve a physical or mental condition”. We understand that EPSDT has to be the first priority for authorization and payment.  Recommendation: If an individual under 21 that has a waiver slot and does not meet the EPSDT requirements, they should be automatically referred to eligibility standards under the DD waiver.  Those that have a waiver slot should have access to the same standards and services whether they are under 21 or over 21. 

CHAPTER 2

Page 22 - the link takes you to VCU website but says the page is not active and the link as noted below on page 23 goes to the VA Code. Still has incorrect form numbers. For example, the DSP Basic competency and health competency have the same form number.  This has never been updated. 

Previous Comment submitted during last review (Nov 2021). A signed assurance document confirms the receipt of instruction in the required training topics. Assurance documents are specific to DSP/DSP Supervisor role. There are two versions and DSPs and DSP supervisors complete the version that matches their role within the organization. These assurance documents are available online at: https://law.lis.virginia.gov/admincode/title12/agency30/chapter122/section9998/

These forms at this link had incorrect form numbers, etc. A vaACCSES member previously let Jason Perkins and Eric Williams know this back in 2021 and this still has not been fixed.

CHAPTER 4

Page 126:

We understand that this section is included to be consistent with DARS.

Here is our recommendation for edits to improve language:

When the individual has demonstrated a period of stability in employment independent of service intervention the individual supports may move to a follow-along status. Stability in employment is determined by the following criteria:

· Intervention has reached a "plateau" or leveled out;

· Individual demonstrates appropriate work behaviors and social skills on the job;

· Individual can perform expected job duties;

· Individual is satisfied with the job and work environment;

· Supervisor is satisfied with the individual’s job performance;

· Necessary worksite modifications and accommodations are in place;

· Transportation to and from work is reliable; and

· Compensation is at or above minimum wage and not less than wages paid by employer for same work performed by people without disabilities.

Follow-Along is defined as those on-going supports necessary to assist an individual with a developmental disability to sustain maintain competitive work in an integrated setting of their choice. Upon reaching stability and follow along, the support team and the individual should discuss whether:

Page 127:
Here’s our recommendations for edits:

·  Vocational or job-related discovery (we are recommending to take this out as its confusing and is covered in the CE section) or assessment such as a situational assessment – when the individual completes attempts work tasks in one or more competitive employment environments in the community. The purpose of the SA is to assist individual in determining vocational options, direction, goals and training strategies.

OVERALL COMMENTS:

1. Appreciate the addition to Respite to not require the submission of a quarterly report when respite is not provided to the individual during the quarter.
2. Consistency between DD Waiver Regs/Manual and Licensing Regs regarding submission of Quarterly Report to Support Coordinator for all services.

For Example:  Ch. IV, p.212 - Respite: 

· The content of each review must be discussed with the individual and family member/caregiver, as applicable and submitted to the Support Coordinator within 10 calendar days following the end of each ISP plan quarter. . .

The requirement should be changed to match up with the licensing regulations found below in 12VAC35-105-675.D.3 which states:

For goals and objectives that were not accomplished by the identified target date, the provider and any appropriate treatment team members shall meet to review the reasons for lack of progress and provide the individual an opportunity to make an informed choice of how to proceed. Documentation of the quarterly review shall be added to the individual's record no later than 15 calendar days from the date the review was due to be completed, with the exception of case management services. Case management quarterly reviews shall be added to the individual's record no later than 30 calendar days from the date the review was due.

3. Barrier to AT Access for children under 21.  By putting AT under the 21 year old age group under EPSDT, the criteria is a barrier to access for this group in getting AT items to “increase ability to control environment, support ISP outcomes as identified, and live safely and independently in the least restrictive community setting”. The EPSDT criteria is more restrictive than the Waiver AT criteria for those under 21 versus those over 21 under the Waiver. EPSDT criteria must be for the treatment of the individual’s disability or to improve a physical or mental condition”. We understand that EPSDT has to be the first priority for authorization and payment.  Recommendation: If an individual under 21 that has a waiver slot and does not meet the EPSDT requirements, they should be automatically referred to eligibility standards under the DD waiver.  Those that have a waiver slot should have access to the same standards and services whether they are under 21 or over 21. 

CHAPTER 2

Page 22 - the link takes you to VCU website but says the page is not active and the link as noted below on page 23 goes to the VA Code. Still has incorrect form numbers. For example, the DSP Basic competency and health competency have the same form number.  This has never been updated. 

Previous Comment submitted during last review (Nov 2021). A signed assurance document confirms the receipt of instruction in the required training topics. Assurance documents are specific to DSP/DSP Supervisor role. There are two versions and DSPs and DSP supervisors complete the version that matches their role within the organization. These assurance documents are available online at: https://law.lis.virginia.gov/admincode/title12/agency30/chapter122/section9998/

These forms at this link had incorrect form numbers, etc. A vaACCSES member previously let Jason Perkins and Eric Williams know this back in 2021 and this still has not been fixed.

CHAPTER 4

Page 126:

We understand that this section is included to be consistent with DARS.

Here is our recommendation for edits to improve language:

When the individual has demonstrated a period of stability in employment independent of service intervention the individual supports may move to a follow-along status. Stability in employment is determined by the following criteria:

· Intervention has reached a "plateau" or leveled out;

· Individual demonstrates appropriate work behaviors and social skills on the job;

· Individual can perform expected job duties;

· Individual is satisfied with the job and work environment;

· Supervisor is satisfied with the individual’s job performance;

· Necessary worksite modifications and accommodations are in place;

· Transportation to and from work is reliable; and

· Compensation is at or above minimum wage and not less than wages paid by employer for same work performed by people without disabilities.

Follow-Along is defined as those on-going supports necessary to assist an individual with a developmental disability to sustain maintain competitive work in an integrated setting of their choice. Upon reaching stability and follow along, the support team and the individual should discuss whether:

Page 127:
Here’s our recommendations for edits:

·  Vocational or job-related discovery (we are recommending to take this out as its confusing and is covered in the CE section) or assessment such as a situational assessment – when the individual completes attempts work tasks in one or more competitive employment environments in the community. The purpose of the SA is to assist individual in determining vocational options, direction, goals and training strategies.

OVERALL COMMENTS:

1. Appreciate the addition to Respite to not require the submission of a quarterly report when respite is not provided to the individual during the quarter.
2. Consistency between DD Waiver Regs/Manual and Licensing Regs regarding submission of Quarterly Report to Support Coordinator for all services.

For Example:  Ch. IV, p.212 - Respite: 

· The content of each review must be discussed with the individual and family member/caregiver, as applicable and submitted to the Support Coordinator within 10 calendar days following the end of each ISP plan quarter. . .

The requirement should be changed to match up with the licensing regulations found below in 12VAC35-105-675.D.3 which states:

For goals and objectives that were not accomplished by the identified target date, the provider and any appropriate treatment team members shall meet to review the reasons for lack of progress and provide the individual an opportunity to make an informed choice of how to proceed. Documentation of the quarterly review shall be added to the individual's record no later than 15 calendar days from the date the review was due to be completed, with the exception of case management services. Case management quarterly reviews shall be added to the individual's record no later than 30 calendar days from the date the review was due.

3. Barrier to AT Access for children under 21.  By putting AT under the 21 year old age group under EPSDT, the criteria is a barrier to access for this group in getting AT items to “increase ability to control environment, support ISP outcomes as identified, and live safely and independently in the least restrictive community setting”. The EPSDT criteria is more restrictive than the Waiver AT criteria for those under 21 versus those over 21 under the Waiver. EPSDT criteria must be for the treatment of the individual’s disability or to improve a physical or mental condition”. We understand that EPSDT has to be the first priority for authorization and payment.  Recommendation: If an individual under 21 that has a waiver slot and does not meet the EPSDT requirements, they should be automatically referred to eligibility standards under the DD waiver.  Those that have a waiver slot should have access to the same standards and services whether they are under 21 or over 21. 

CHAPTER 2

Page 22 - the link takes you to VCU website but says the page is not active and the link as noted below on page 23 goes to the VA Code. Still has incorrect form numbers. For example, the DSP Basic competency and health competency have the same form number.  This has never been updated. 

Previous Comment submitted during last review (Nov 2021). A signed assurance document confirms the receipt of instruction in the required training topics. Assurance documents are specific to DSP/DSP Supervisor role. There are two versions and DSPs and DSP supervisors complete the version that matches their role within the organization. These assurance documents are available online at: https://law.lis.virginia.gov/admincode/title12/agency30/chapter122/section9998/

These forms at this link had incorrect form numbers, etc. A vaACCSES member previously let Jason Perkins and Eric Williams know this back in 2021 and this still has not been fixed.

CHAPTER 4

Page 126:

We understand that this section is included to be consistent with DARS.

Here is our recommendation for edits to improve language:

When the individual has demonstrated a period of stability in employment independent of service intervention the individual supports may move to a follow-along status. Stability in employment is determined by the following criteria:

· Intervention has reached a "plateau" or leveled out;

· Individual demonstrates appropriate work behaviors and social skills on the job;

· Individual can perform expected job duties;

· Individual is satisfied with the job and work environment;

· Supervisor is satisfied with the individual’s job performance;

· Necessary worksite modifications and accommodations are in place;

· Transportation to and from work is reliable; and

· Compensation is at or above minimum wage and not less than wages paid by employer for same work performed by people without disabilities.

Follow-Along is defined as those on-going supports necessary to assist an individual with a developmental disability to sustain maintain competitive work in an integrated setting of their choice. Upon reaching stability and follow along, the support team and the individual should discuss whether:

Page 127:
Here’s our recommendations for edits:

·  Vocational or job-related discovery (we are recommending to take this out as its confusing and is covered in the CE section) or assessment such as a situational assessment – when the individual completes attempts work tasks in one or more competitive employment environments in the community. The purpose of the SA is to assist individual in determining vocational options, direction, goals and training strategies.

OVERALL COMMENTS:

1. Appreciate the addition to Respite to not require the submission of a quarterly report when respite is not provided to the individual during the quarter.
2. Consistency between DD Waiver Regs/Manual and Licensing Regs regarding submission of Quarterly Report to Support Coordinator for all services.

For Example:  Ch. IV, p.212 - Respite: 

· The content of each review must be discussed with the individual and family member/caregiver, as applicable and submitted to the Support Coordinator within 10 calendar days following the end of each ISP plan quarter. . .

The requirement should be changed to match up with the licensing regulations found below in 12VAC35-105-675.D.3 which states:

For goals and objectives that were not accomplished by the identified target date, the provider and any appropriate treatment team members shall meet to review the reasons for lack of progress and provide the individual an opportunity to make an informed choice of how to proceed. Documentation of the quarterly review shall be added to the individual's record no later than 15 calendar days from the date the review was due to be completed, with the exception of case management services. Case management quarterly reviews shall be added to the individual's record no later than 30 calendar days from the date the review was due.

3. Barrier to AT Access for children under 21.  By putting AT under the 21 year old age group under EPSDT, the criteria is a barrier to access for this group in getting AT items to “increase ability to control environment, support ISP outcomes as identified, and live safely and independently in the least restrictive community setting”. The EPSDT criteria is more restrictive than the Waiver AT criteria for those under 21 versus those over 21 under the Waiver. EPSDT criteria must be for the treatment of the individual’s disability or to improve a physical or mental condition”. We understand that EPSDT has to be the first priority for authorization and payment.  Recommendation: If an individual under 21 that has a waiver slot and does not meet the EPSDT requirements, they should be automatically referred to eligibility standards under the DD waiver.  Those that have a waiver slot should have access to the same standards and services whether they are under 21 or over 21. 

CHAPTER 2

Page 22 - the link takes you to VCU website but says the page is not active and the link as noted below on page 23 goes to the VA Code. Still has incorrect form numbers. For example, the DSP Basic competency and health competency have the same form number.  This has never been updated. 

Previous Comment submitted during last review (Nov 2021). A signed assurance document confirms the receipt of instruction in the required training topics. Assurance documents are specific to DSP/DSP Supervisor role. There are two versions and DSPs and DSP supervisors complete the version that matches their role within the organization. These assurance documents are available online at: https://law.lis.virginia.gov/admincode/title12/agency30/chapter122/section9998/

These forms at this link had incorrect form numbers, etc. A vaACCSES member previously let Jason Perkins and Eric Williams know this back in 2021 and this still has not been fixed.

CHAPTER 4

Page 126:

We understand that this section is included to be consistent with DARS.

Here is our recommendation for edits to improve language:

When the individual has demonstrated a period of stability in employment independent of service intervention the individual supports may move to a follow-along status. Stability in employment is determined by the following criteria:

· Intervention has reached a "plateau" or leveled out;

· Individual demonstrates appropriate work behaviors and social skills on the job;

· Individual can perform expected job duties;

· Individual is satisfied with the job and work environment;

· Supervisor is satisfied with the individual’s job performance;

· Necessary worksite modifications and accommodations are in place;

· Transportation to and from work is reliable; and

· Compensation is at or above minimum wage and not less than wages paid by employer for same work performed by people without disabilities.

Follow-Along is defined as those on-going supports necessary to assist an individual with a developmental disability to sustain maintain competitive work in an integrated setting of their choice. Upon reaching stability and follow along, the support team and the individual should discuss whether:

Page 127:
Here’s our recommendations for edits:

·  Vocational or job-related discovery (we are recommending to take this out as its confusing and is covered in the CE section) or assessment such as a situational assessment – when the individual completes attempts work tasks in one or more competitive employment environments in the community. The purpose of the SA is to assist individual in determining vocational options, direction, goals and training strategies.

OVERALL COMMENTS:

1. Appreciate the addition to Respite to not require the submission of a quarterly report when respite is not provided to the individual during the quarter.
2. Consistency between DD Waiver Regs/Manual and Licensing Regs regarding submission of Quarterly Report to Support Coordinator for all services.

For Example:  Ch. IV, p.212 - Respite: 

· The content of each review must be discussed with the individual and family member/caregiver, as applicable and submitted to the Support Coordinator within 10 calendar days following the end of each ISP plan quarter. . .

The requirement should be changed to match up with the licensing regulations found below in 12VAC35-105-675.D.3 which states:

For goals and objectives that were not accomplished by the identified target date, the provider and any appropriate treatment team members shall meet to review the reasons for lack of progress and provide the individual an opportunity to make an informed choice of how to proceed. Documentation of the quarterly review shall be added to the individual's record no later than 15 calendar days from the date the review was due to be completed, with the exception of case management services. Case management quarterly reviews shall be added to the individual's record no later than 30 calendar days from the date the review was due.

3. Barrier to AT Access for children under 21.  By putting AT under the 21 year old age group under EPSDT, the criteria is a barrier to access for this group in getting AT items to “increase ability to control environment, support ISP outcomes as identified, and live safely and independently in the least restrictive community setting”. The EPSDT criteria is more restrictive than the Waiver AT criteria for those under 21 versus those over 21 under the Waiver. EPSDT criteria must be for the treatment of the individual’s disability or to improve a physical or mental condition”. We understand that EPSDT has to be the first priority for authorization and payment.  Recommendation: If an individual under 21 that has a waiver slot and does not meet the EPSDT requirements, they should be automatically referred to eligibility standards under the DD waiver.  Those that have a waiver slot should have access to the same standards and services whether they are under 21 or over 21. 

CHAPTER 2

Page 22 - the link takes you to VCU website but says the page is not active and the link as noted below on page 23 goes to the VA Code. Still has incorrect form numbers. For example, the DSP Basic competency and health competency have the same form number.  This has never been updated. 

Previous Comment submitted during last review (Nov 2021). A signed assurance document confirms the receipt of instruction in the required training topics. Assurance documents are specific to DSP/DSP Supervisor role. There are two versions and DSPs and DSP supervisors complete the version that matches their role within the organization. These assurance documents are available online at: https://law.lis.virginia.gov/admincode/title12/agency30/chapter122/section9998/

These forms at this link had incorrect form numbers, etc. A vaACCSES member previously let Jason Perkins and Eric Williams know this back in 2021 and this still has not been fixed.

CHAPTER 4

Page 126:

We understand that this section is included to be consistent with DARS.

Here is our recommendation for edits to improve language:

When the individual has demonstrated a period of stability in employment independent of service intervention the individual supports may move to a follow-along status. Stability in employment is determined by the following criteria:

· Intervention has reached a "plateau" or leveled out;

· Individual demonstrates appropriate work behaviors and social skills on the job;

· Individual can perform expected job duties;

· Individual is satisfied with the job and work environment;

· Supervisor is satisfied with the individual’s job performance;

· Necessary worksite modifications and accommodations are in place;

· Transportation to and from work is reliable; and

· Compensation is at or above minimum wage and not less than wages paid by employer for same work performed by people without disabilities.

Follow-Along is defined as those on-going supports necessary to assist an individual with a developmental disability to sustain maintain competitive work in an integrated setting of their choice. Upon reaching stability and follow along, the support team and the individual should discuss whether:

Page 127:
Here’s our recommendations for edits:

·  Vocational or job-related discovery (we are recommending to take this out as its confusing and is covered in the CE section) or assessment such as a situational assessment – when the individual completes attempts work tasks in one or more competitive employment environments in the community. The purpose of the SA is to assist individual in determining vocational options, direction, goals and training strategies.

DD Waiver Manual – Chap 2 and Chap 4

OVERALL COMMENTS:

1. Appreciate the addition to Respite to not require the submission of a quarterly report when respite is not provided to the individual during the quarter.
2. Consistency between DD Waiver Regs/Manual and Licensing Regs regarding submission of Quarterly Report to Support Coordinator for all services.

For Example:  Ch. IV, p.212 - Respite: 

· The content of each review must be discussed with the individual and family member/caregiver, as applicable and submitted to the Support Coordinator within 10 calendar days following the end of each ISP plan quarter. . .

The requirement should be changed to match up with the licensing regulations found below in 12VAC35-105-675.D.3 which states:

For goals and objectives that were not accomplished by the identified target date, the provider and any appropriate treatment team members shall meet to review the reasons for lack of progress and provide the individual an opportunity to make an informed choice of how to proceed. Documentation of the quarterly review shall be added to the individual's record no later than 15 calendar days from the date the review was due to be completed, with the exception of case management services. Case management quarterly reviews shall be added to the individual's record no later than 30 calendar days from the date the review was due.

3. Barrier to AT Access for children under 21.  By putting AT under the 21 year old age group under EPSDT, the criteria is a barrier to access for this group in getting AT items to “increase ability to control environment, support ISP outcomes as identified, and live safely and independently in the least restrictive community setting”. The EPSDT criteria is more restrictive than the Waiver AT criteria for those under 21 versus those over 21 under the Waiver. EPSDT criteria must be for the treatment of the individual’s disability or to improve a physical or mental condition”. We understand that EPSDT has to be the first priority for authorization and payment.  Recommendation: If an individual under 21 that has a waiver slot and does not meet the EPSDT requirements, they should be automatically referred to eligibility standards under the DD waiver.  Those that have a waiver slot should have access to the same standards and services whether they are under 21 or over 21. 

CHAPTER 2

Page 22 - the link takes you to VCU website but says the page is not active and the link as noted below on page 23 goes to the VA Code. Still has incorrect form numbers. For example, the DSP Basic competency and health competency have the same form number.  This has never been updated. 

Previous Comment submitted during last review (Nov 2021). A signed assurance document confirms the receipt of instruction in the required training topics. Assurance documents are specific to DSP/DSP Supervisor role. There are two versions and DSPs and DSP supervisors complete the version that matches their role within the organization. These assurance documents are available online at: https://law.lis.virginia.gov/admincode/title12/agency30/chapter122/section9998/

These forms at this link had incorrect form numbers, etc. A vaACCSES member previously let Jason Perkins and Eric Williams know this back in 2021 and this still has not been fixed.

CHAPTER 4

Page 126:

We understand that this section is included to be consistent with DARS.

Here is our recommendation for edits to improve language:

When the individual has demonstrated a period of stability in employment independent of service intervention the individual supports may move to a follow-along status. Stability in employment is determined by the following criteria:

· Intervention has reached a "plateau" or leveled out;

· Individual demonstrates appropriate work behaviors and social skills on the job;

· Individual can perform expected job duties;

· Individual is satisfied with the job and work environment;

· Supervisor is satisfied with the individual’s job performance;

· Necessary worksite modifications and accommodations are in place;

· Transportation to and from work is reliable; and

· Compensation is at or above minimum wage and not less than wages paid by employer for same work performed by people without disabilities.

Follow-Along is defined as those on-going supports necessary to assist an individual with a developmental disability to sustain maintain competitive work in an integrated setting of their choice. Upon reaching stability and follow along, the support team and the individual should discuss whether:

Page 127:
Here’s our recommendations for edits:

·  Vocational or job-related discovery (we are recommending to take this out as its confusing and is covered in the CE section) or assessment such as a situational assessment – when the individual completes attempts work tasks in one or more competitive employment environments in the community. The purpose of the SA is to assist individual in determining vocational options, direction, goals and training strategies.

In Chapter IV, p. 212 regarding the submission of quarterly reviews, the proposed language states: 

The content of each review must be discussed with the individual and family member/caregiver, as applicable and submitted to the Support Coordinator within 10 calendar days following the end of each ISP plan quarter. . .

 However, the licensing regulations for respite provide in 12VAC35-105-675.D.3 a 15 day window for submitting quarterly reviews as follows:

 Documentation of the quarterly review shall be added to the individual's record no later than 15 calendar days from the date the review was due to be completed, with the exception of case management services. Case management quarterly reviews shall be added to the individual's record no later than 30 calendar days from the date the review was due.

As providers we need consistency between DBHDS and DMAS in order to eliminate confusion.

Jill's House appreciates the clarity provided in the manual that Quarterly Reviews are not required during quarters in which respite was not provided.

As a provider that is a Department for the Aging and Rehabilitative Services vendor, which has held a national three-year accreditation from the Commission on Accreditation of Rehabilitation Facilities (CARF) for over 30 years, we are intrigued with the new content of chapter II of the provider manual.  However, as a surveyor for CARF myself, this option of substituting the three- year CARF report with no recommendation around the staff competency training, in lieu of DSP training focused on developing specific competencies, seems to be less effective at providing direct service staff with the tools needed to be successful in serving this population.  CARF accreditation can and is granted to organizations who serve a multitude of individuals, not just individuals with disabilities.  Furthermore, the standards that CARF has on competency training are not one in the same with the DSP training and the CARF standard can be met in many ways.  Therefore, in our opinion, it is not in the best interest of the person receiving services, nor the direct service provider staff, to not receive the more robust DSP training. 

We are expressing concern for how providers would address skill development, job knowledge and industry best practices of DSP staff if they do not have this training opportunity.  Generally, DSP front-line staff earn one of the lowest wages in the industry, due to reimbursement rates.  Recruitment and retention for these positions has also become increasingly difficult.  Credentials or certification and experience is essential to raising the level care to the individuals served by DSPs.  

Specifically, we would request that the manual content be further elaborated to specifically identify: (1) the process by which providers must submit the results from their CARF surveys including recommendations received to the Department of Behavioral Health and Developmental Services, (2) the process that DBHDS will verify that there are no recommendations for the standards that address staff competency and communicate this approval to providers, (3) the process and consequence that DBHDS will apply for a provider who has one or more recommendation(s) in an area of competency training in their CARF survey (for example, is a recommendation competency based safety training not acceptable or is this specific to standards in sections 2, 3 and 4 of the standards manual) , and (4) further clarification on the applicability of the first sentence of this paragraph in the chapter, to the later sentence regarding CARF accreditation, as the use of furthermore appears to imply that one is reliant on or a pre-requisite of the other.  The word “competency” utilized by CARF, appears to be vastly different from the intention of the competency training as currently required from DBHDS of providers (e.g. DSP training).

Thank you for the opportunity to provide comment and consideration to this feedback.

OVERALL COMMENTS:

1. Appreciate the addition to Respite to not require the submission of a quarterly report when respite is not provided to the individual during the quarter.
2. Consistency between DD Waiver Regs/Manual and Licensing Regs regarding submission of Quarterly Report to Support Coordinator for all services.

For Example:  Ch. IV, p.212 - Respite: 

· The content of each review must be discussed with the individual and family member/caregiver, as applicable and submitted to the Support Coordinator within 10 calendar days following the end of each ISP plan quarter. . .

The requirement should be changed to match up with the licensing regulations found below in 12VAC35-105-675.D.3 which states:

For goals and objectives that were not accomplished by the identified target date, the provider and any appropriate treatment team members shall meet to review the reasons for lack of progress and provide the individual an opportunity to make an informed choice of how to proceed. Documentation of the quarterly review shall be added to the individual's record no later than 15 calendar days from the date the review was due to be completed, with the exception of case management services. Case management quarterly reviews shall be added to the individual's record no later than 30 calendar days from the date the review was due.

3. Barrier to AT Access for children under 21.  By putting AT under the 21 year old age group under EPSDT, the criteria is a barrier to access for this group in getting AT items to “increase ability to control environment, support ISP outcomes as identified, and live safely and independently in the least restrictive community setting”. The EPSDT criteria is more restrictive than the Waiver AT criteria for those under 21 versus those over 21 under the Waiver. EPSDT criteria must be for the treatment of the individual’s disability or to improve a physical or mental condition”. We understand that EPSDT has to be the first priority for authorization and payment.  Recommendation: If an individual under 21 that has a waiver slot and does not meet the EPSDT requirements, they should be automatically referred to eligibility standards under the DD waiver.  Those that have a waiver slot should have access to the same standards and services whether they are under 21 or over 21. 

CHAPTER 2

Page 22 - the link takes you to VCU website but says the page is not active and the link as noted below on page 23 goes to the VA Code. Still has incorrect form numbers. For example, the DSP Basic competency and health competency have the same form number.  This has never been updated. 

Previous Comment submitted during last review (Nov 2021). A signed assurance document confirms the receipt of instruction in the required training topics. Assurance documents are specific to DSP/DSP Supervisor role. There are two versions and DSPs and DSP supervisors complete the version that matches their role within the organization. These assurance documents are available online at: https://law.lis.virginia.gov/admincode/title12/agency30/chapter122/section9998/

These forms at this link had incorrect form numbers, etc. A vaACCSES member previously let Jason Perkins and Eric Williams know this back in 2021 and this still has not been fixed.

CHAPTER 4

Page 126:

We understand that this section is included to be consistent with DARS.

Here is our recommendation for edits to improve language:

When the individual has demonstrated a period of stability in employment independent of service intervention the individual supports may move to a follow-along status. Stability in employment is determined by the following criteria:

· Intervention has reached a "plateau" or leveled out;

· Individual demonstrates appropriate work behaviors and social skills on the job;

· Individual can perform expected job duties;

· Individual is satisfied with the job and work environment;

· Supervisor is satisfied with the individual’s job performance;

· Necessary worksite modifications and accommodations are in place;

· Transportation to and from work is reliable; and

· Compensation is at or above minimum wage and not less than wages paid by employer for same work performed by people without disabilities.

Follow-Along is defined as those on-going supports necessary to assist an individual with a developmental disability to sustain maintain competitive work in an integrated setting of their choice. Upon reaching stability and follow along, the support team and the individual should discuss whether:

Page 127:
Here’s our recommendations for edits:

·  Vocational or job-related discovery (we are recommending to take this out as its confusing and is covered in the CE section) or assessment such as a situational assessment – when the individual completes attempts work tasks in one or more competitive employment environments in the community. The purpose of the SA is to assist individual in determining vocational options, direction, goals and training strategies.