Premium Payments for VR Services

Discussion Paper

Background

Section 361.50 of 34 CFR requires the State unit to establish and maintain written policies to govern the rates of payment for all purchased vocational rehabilitation (VR) services. The State unit may establish a fee schedule designed to ensure a reasonable cost to the program for each service, while ensuring that the schedule is: “(2)(i) not so low as to effectively deny an individual a necessary service; and (ii) not absolute and permits exceptions so that individual needs can be addressed. States are prohibited from placing absolute dollar limits on specific service categories or on the total services provided to an individual.

Certain services must be delivered by individuals with a higher level of education and/or training including certain services to customers with disabilities such as Autism, deafness, and blindness. Other populations, such as customers with criminal backgrounds, may similarly place unique staffing demands upon providers. The demand for enhanced skills and certifications imposes additional costs upon providers.

In FY 2013, the Division of Rehabilitation Services (DRS) appointed a work group to research trends related regarding customer employment outcomes achieved by community rehabilitation programs. Trends identified included:

  • Low interest from providers to work with individuals with criminal backgrounds;
  • Under employment and low placement rates for customers with higher education as well as placement into lower wage positions for customers in general, and
  • The higher cost incurred by the program to provide third-party interpreters for customers who are deaf when they received a job placement or job training from the employment service provider.

As the result of workgroup’s findings, DRS introduced premium payments in FY 2014 to encourage providers to work with customers with criminal histories, to compensate providers for additional efforts associated with securing a higher-wage position and/or professional level position for a customer, and to decrease the cost of purchasing deaf interpreter services when purchasedsimultaneously with an employment service. DRS implemented the following categories of premium payments for Bundled Job Placement Services, Job Skills Training and Supported Employment:

  1. Criminal Background Premium
  2. Wage Premium (at least $16/hour and 20 hours/week)
  3. Professional Placement Premium
  4. Deaf Service Premium

In FY 2015 DRS added a fifth premium payment category for providers who obtained the necessary skills and credentials to effectively serve individuals with Autism:

  1. Autism

Premiums are paid only after a service has been successfully completed. Current data on premium payments indicates that they are making a positive impact on the trends identified in FY 2013. Cases in which providers received a premium payment had higher successful closure rates.

Issues

Currently staff in the Rehabilitation Services Division (RSD) and the Blind Services Division (BSD) are working under separate program and provider standards manuals. TWC staff is creating a single Vocational Rehabilitation Services Manual (VRSM) and Standards for Providers (SFP) manual in anticipation of the combination of the two VR divisions by October 1, 2017. As staff creates the combined manuals they have identified sections that require alignment between the two divisions as well as policies that require improvement or updating. For premium payments offered to providers, staff has identified the following three issues:

Issue 1

BSD does not have premium payments; therefore, BSD providers who work with individuals who are blind and visually impaired and who also fall within the five premium payment categories are not able to receive premium payments.

Issue 2

BSD has historically reimbursed providers for travel expenses associated with traveling to outlying areas, including rural areas, to provide services to customers. This practice was implemented due to the lack of providers available to serve customers with visual impairment and blindness. RSD has not offered reimbursement of travel expenses for providers, but has experienced challenges with securing a provider for customers in rural, more underserved areas of the state. Without a way to ensure that travel costs can be covered, there is no incentive for providers to deliver services to customers within rural underserved areas. There is a need for a consistent approach to addressing this within the combined VR division.

Decision Points

To address the issues identified above, staff recommends the following revisions for inclusion in the combined Standards for Providers manual.

  1. To ensure quality services and supports are provided to customers, staff recommends that the following premiums be made available to providers serving all eligible customers receiving the services which qualify for premiums, including providers serving individuals who are blind or visually impaired:
  1. Criminal Background Premium
  2. Wage Premium (at least $16/hour and 20 hours/week)
  3. Professional Placement Premium
  4. Deaf Service Premium
  5. Autism Premium
  1. To ensure that providers are available to serve customers in outlying areas and rural communities, staff recommends adding a Travel Premium that would apply based on the distance a provider would travel to provide services to a customer. The proposed premium payment provides a method to reimburse mileage. The following criteria would apply to Travel Premium:
  2. There is no qualified provider to meet the customer’s need within a 50 mile radius of the customer’s location;
  3. A minimum of two hours of service must be provided to the customer for any visit in which a premium is paid;
  4. Calculation of the Travel Premium is based on the distance between the provider’s business address and the city/town of the customer’s residence or service location. MapQuest Route Finder would be applied by the provider to identify the shortest distance and round-trip option; and
  5. Mileage incurred within the customer’s city/town does not count toward the calculation of the Travel Premium amount.

Staff recommends that the proposed Travel Premium be available for the following services:

  • Assistive Technology for Sighted-related Disabilities Services,
  • Blind Independent Living for Older Adult Services
  • Bundled Job Placement Services
  • Combined Situational Assessments and Work Samples Service
  • Diabetes Self-Management Services
  • Environmental Work Assessments
  • Non-Bundled Job Placement Services
  • Orientation and Mobility Services
  • Personal Social Adjustment Training Services
  • Supported Employment Services
  • Vocational Adjustment Training Services
  • Vocational Assessments
  • Work Experience Services

DP_Standards_Chap 20_Premiums.docx

Agenda Item: 06/11/17 Commission Meeting

1