Supported Employment Services for VR Customers

Discussion Paper

Background

The goal of Supported Employment Services is to provide the necessary training and support to a customer with the most significant disabilities, to ensure that customer has obtained stability in competitive integrated employment and can continue in that employment with natural supports after conclusion of Vocational Rehabilitation (VR) services.

Supported Employment Services are provided to individuals that require intensive employment supports, including initial placement and stabilization in the workplace. Supported Employment Services offer continuing assistance from an employment specialist to maintain long-term employment for individuals who have previously been unable to succeed in employment. This support includes building extended, ongoing supports with agencies and partners outside of VR to assist a person in maintaining employment.

Title IV of the Workforce Innovation and Opportunity Act (WIOA) contains theRehabilitation Act of 1973 as amended. WIOA defines the services of “supported employment”as“competitive integrated employment, including customized employment, or employment in an integrated work setting in which an individual with a most significant disability, including a youth with a most significant disability, is working on a short-term basis toward competitive integrated employment, that is individualized and customized, consistent with the unique strengths, abilities, interests, and informed choice of the individual, including with ongoing support services for individuals with the most significant disabilities—

(1)(i) For whom competitive integrated employment has not historically occurred; or

(ii) For whom competitive integrated employment has been interrupted or intermittent as a result of a significant disability; and

(2) Who, because of the nature and severity of the disability, needs intensive supported employment services, and extended services after the transition from support provided by the designated State unit in order to perform the work.

(53 CFR §361.5(c)(9); Rehabilitation Act of 1973, as amended,§§7(38), 7(39), 12(c), and 602; 29 USC §705(38) and§705(39), §709(c), and §795(g))

WIOAestablishes a separate grant to states for Supported Employment. “Under the State supported employment services program, the Secretary provides grants to assist States in developing and implementing collaborative programs with appropriate entities to provide programs of supported employment services for individuals with the most significant disabilities, including youth with the most significant disabilities, to enable them to achieve an employment outcome of supported employment in competitive integrated employment. Grants made under the State supported employment services program supplement a State’s vocational rehabilitation program grants under 34 CFR part 361.” In Federal Fiscal Year 2016, Texas received $1.9 million for the Supported Employment grant. Additionally, VR grant funds are available as needed to pay for Supported Employment Services. Texas VR expended approximately$10.25 million in Supported Employment Services in FFY 2016.

In Texas, Supported Employment Services are contracted services provided by Community Rehabilitation Providers (CRPs). Vocational Rehabilitation Services pays CRPs based on achievement of specific benchmarks. A provider is paid when a customer completes a benchmark and when VR staff receives the appropriate documentation of that completed benchmark. There are six benchmarks in Supported Employment Services that must be completed for a successful customer outcome at case closure:

  • Benchmark 1A: Supported Employment Assessment (SEA) and SEA Meeting
  • Benchmark 1B: Supported Employment Service Plan
  • Benchmark 2: Job Placement and Completion of 5 days worked and Supported Employment Service Plan
  • Benchmark 3: 28 days (4 weeks) of Job Maintenance
  • Benchmark 4: 56 days (8 weeks) of Job Maintenance
  • Benchmark 5: Job Stability
  • At least 56 days of employment
  • Completion of job stability meeting
  • Benchmark 6: Service Closure
  • 116 cumulative days of employment
  • 60 cumulative days after achievement of Benchmark 5, Job Stability

Issue

The Supported Employment policy in the current Standards for Providers Manual defines and measures ‘stability’ in a manner that is inconsistent with the federally-defined requirements for a customer’s case to be closed with a successful VR employment outcome. While the definition of stability and VR case closure (also known as VR exit) are not required to be the same, the current inconsistency in the two is creating inefficiency and repeat work in some instances. In addition, the procedure for Supported Employment benchmarks in the current Standards for Providers Manual lacks clarity for CRPs regardingwhen to collect information and when and how to count the days of stability.

As a result of these inconsistencies, CRPs may conclude their work with a customer and receive their final benchmark payment after the customer has been employed for only 60 days while a VR customer case may not be closed as successfully employed until the customer has been employed for 90 days. Therefore, a CRP may conclude their work with a customer 30 days before VR considers a customer employment outcome to be successful. When a customer is not able to maintain competitive integrated employment for 90 days, that customer’s employment is not stable and the outcome of VR services is not successful for that customer. When working with customers with multiple and significant disabilities, it is particularly important to provide ongoing support and follow up throughout the entire 90-day period to ensure that the employment placement is stable and likely to continue.

Because the current Standard for Providers allows for completion of CRP Supported Employment Services at 60 days after employment, when a customer encounters difficulties during the 60-90 day window the CRP, or a different CRP, must be reengaged and some Supported Employment Services must be repeated and benchmarks may be paid for those repeated services.

Recommendations

Policy Change

Staff recommends the job stability time framefor CRP Supported Employment Services be redefined from 60 days to 90 days. The proposed change will require the providerto continue workingwith the customer for an additional 30 days. This will ensure that the CRP’s date of closure aligns with federal law and regulation regarding when a customer’s case may be closed with a successful employment outcome.The increased stability timeframe will alsobetter ensure that a customer is stable in employment and that extended supports are in place to enable the customer to retain that employment after closure of the VR case. Supported Employment Services will result in more successful outcomes and fewer repeated benchmarks and benchmark payments.

Procedural Changes

The procedural changesthat accompany the Supported Employment policy revision will includesimplified forms. The current Supported Employment forms have been identified as lengthy and repetitive. The revised forms remove duplication and are more concise.

The recommended procedural changes also clarify and provide methods to collect information, specify content on new forms, verify that it is individualized to each customer, and add a time sheet to document hours worked.

Input from the Rehabilitation Council of Texas

The Rehabilitation Council of Texas (RCT) was given the opportunity to review and provide feedback on Supported Employment Services. On March 7, 2017, RCT noted that it supports the proposed changes to Supported Employment Services.

DP VR Standards Rev_Supported Empl Svcs 4-11-17.docx

Agenda Item: 04/11/17 Commission Meeting 1