Prevocational Services

 In 2015 The Centers for Medicare and Medicaid mandated that states adopt the following definitions of services.  With regard to Prevococation services please note the highlighted section that states that Prevocational services are time limited, but it is up to the person centered process and team to decide that time frame is.

 

Here in CT, Dept. of Social Services has determined that  brain injury survivors have only 2 years in which to accomplish the task of becoming employable or they will lose the prevocational training they so desperately need.

 

CMS Guidelines:
 
Prevocational Services Core Service Definition:

Services that provide learning and work experiences, including volunteer work, where the individual can develop general, non-job-task-specific strengths and skills that contribute to employability in paid employment in integrated community settings.  Services are expected to occur over a defined period of time and with specific outcomes to be achieved, as determined by the individual and his/her service and supports planning team through an ongoing person-centered planning process.

    
Individuals receiving prevocational services must have employment-related goals in their personcentered services and supports plan; the general habilitation activities must be designed to support such employment goals. Competitive, integrated employment in the community for which an individual is compensated at or above the minimum wage, but not less than the customary wage and level of benefits paid by the employer for the same or similar work performed by individuals without disabilities is considered to be the optimal outcome of prevocational services.    
Prevocational services should enable each individual to attain the highest level of work in the most integrated setting and with the job matched to the individual’s interests, strengths, priorities, abilities, and capabilities, while following applicable federal wage guidelines. Services are intended to develop and teach general skills; Examples include, but are not limited to: ability to communicate effectively with supervisors, co-workers and customers; generally accepted community workplace conduct and dress; ability to follow directions; ability to attend to tasks; workplace problem solving skills and strategies; general workplace safety and mobility training.  

 
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Participation in prevocational services is not a required pre-requisite for individual or small group supported employment services provided under the waiver.  Many individuals, particularly those transitioning from school to adult activities, are likely to choose to go directly into supported employment. Similarly, the evidence-based Individual Placement and Support (IPS) model of supported employment for individuals with behavioral health conditions emphasizes rapid job placement in lieu of prevocational services.   Documentation is maintained that the service is not available under a program funded under section 110 of the Rehabilitation Act of 1973 or the IDEA (20 U.S.C. 1401 et seq.).  


Instructions

 

• Supplement or modify the core definition as appropriate to incorporate the specific service elements furnished under the waiver.

• Prevocational services may be furnished in a variety of locations in the community and are not limited to fixed-site facilities.  Specify in the service definition where these services are furnished.

• If transportation between the participant's place of residence and the prevocational service site/s is provided as a component part of prevocational services and the cost of this transportation is included in the rate paid to providers of prevocational services, the service definition must include a statement to that effect.

• Specify in the definition how the determination is made that the services furnished to the participant are prevocational rather than vocational in nature in accordance with 42 CFR §440.180(c)(2)(i).  


Guidance

 

• Pre-vocational Services include activities that are not primarily directed at teaching skills to perform a particular job, but at underlying habilitative goals (e.g., attention span, motor skills, interpersonal relations with co-workers and supervisors) that are associated with building skills necessary to perform work and optimally to perform competitive, integrated employment.  Vocational services, which are not covered through waivers, are services that teach job task specific skills required by a participant for the primary purpose of completing those tasks for a specific facility based job and are not delivered in an integrated work setting through supported employment. The distinction between vocational and pre-vocational services is that pre-vocational services, regardless of setting, are delivered for the purpose of furthering habilitation goals that will lead to greater opportunities for competitive and integrated employment and career advancement at or above minimum wage.  These goals are described in the individual’s person centered services and supports plan and are designed to teach skills that will lead to integrated competitive employment. • A person receiving pre-vocational services may pursue employment opportunities at any time to enter the general work force. Pre-vocational services are intended to assist individuals to enter the general workforce.   • Individuals participating in prevocational services may be compensated in accordance with applicable Federal laws and regulations and the optimal outcome of the provision of prevocational services is permanent integrated employment at or above the minimum wage in the community.  • All prevocational and supported employment service options should be reviewed and considered as a component of an individual’s person-centered services and supports plan no less than annually, more frequently as necessary or as requested by the individual. These services and supports should be designed to support successful employment outcomes consistent with the individual’s goals. 


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• Personal care/assistance may be a component of prevocational services, but may not comprise the entirety of the service. • Individuals who receive prevocational services may also receive educational, supported employment and/or day habilitation services. A participant’s person-centered services and supports plan may include two or more types of non-residential habilitation services. However, different types of non-residential habilitation services may not be billed during the same period of the day.   •If States wish to cover “career planning” activities they may choose to include it as a component part of pre-vocational services or it may be broken out as a separate stand alone service definition.  • Prevocational services may include volunteer work, such as learning and training activities that prepare a person for entry into the paid workforce. • Prevocational services may be furnished to any individual who requires and chooses them through a person-centered planning process.  They are not limited to persons with intellectual or developmental disabilities.  
Supported Employment -Individual Employment Support  Core Service Definition Supported Employment -Individual Employment Support services are the ongoing supports to participants who, because of their disabilities, need intensive on-going support to obtain and maintain an individual job in competitive or customized employment, or self-employment, in an integrated work setting in the general workforce for which an individual is compensated at or above the minimum wage, but not less than the customary wage and level of benefits paid by the employer for the same or similar work performed by individuals without disabilities. The outcome of this service is sustained paid employment at or above the minimum wage in an integrated setting in the general workforce, in a job that meets personal and career goals.   
Supported employment services can be provided through many different service models.  Some of these models can include evidence-based supported employment for individuals with mental illness, or customized employment for individuals with significant disabilities.  States may define other models of individualized supported employment that promote community inclusion and integrated employment.    
Supported employment individual employment supports may also include support to establish or maintain self-employment, including home-based self-employment. Supported employment services are individualized and may include any combination of the following services: vocational/job-related discovery or assessment, person-centered employment planning, job placement, job development, negotiation with prospective employers, job analysis, job carving, training and systematic instruction, job coaching, benefits support, training and  planning, transportation, asset development and career advancement services, and other workplace support services including services not specifically related to job skill training that enable the waiver participant to be successful in integrating into the job setting.   Documentation is maintained that the service is not available under a program funded under section 110 of the Rehabilitation Act of 1973 or the IDEA (20 U.S.C. 1401 et seq.). Federal financial participation is not claimed for incentive payments, subsidies, or unrelated vocational training expenses such as the following: 


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1. Incentive payments made to an employer to encourage or subsidize the employer's participation in supported employment; or 2. Payments that are passed through to users of supported employment services.  
Instructions • Supplement or modify the core definition as appropriate to incorporate the specific service elements furnished in the waiver. • Supported employment individual employment supports is not intended for people working in mobile work crews of small groups of people with disabilities in the community.  That type of work support is addressed in the core service definition for Supported Employment Small Group employment support.   • If transportation between the participant's place of residence and the employment site is a component part of supported employment individual employment supports services and the cost of this transportation is included in the rate paid to providers of supported employment individual employment supports services, the service definition must include a statement to that effect.  
Guidance • Statewide rate setting methodologies, which are further described in I-2-a of the waiver application may be used to embrace new models of support that  help a person obtain and maintain integrated employment in the community. These may include co-worker support models, payments for work milestones, such as length of time on the job, number of hours the participant works, etc.   Payments for work milestones are not incentive payments that are made to an employer to encourage or subsidize the employer’s hiring an individual with disabilities, which is not permissible.   • Supported employment individual employment supports does not include facility based, or other similar types of vocational services furnished in specialized facilities that are not a part of the general workplace. • In addition to the need for an appropriate job match that meets the individual’s skills and interests, individuals with the most significant disabilities may also need long term employment support to successfully maintain a job due to the ongoing nature of the waiver participant’s support needs, changes in life situations, or evolving and changing job responsibilities. • All prevocational and supported employment service options should be reviewed and considered as a component of an individual’s person-centered services and supports plan no less than annually, more frequently as necessary or as requested by the individual. These services and supports should be designed to support successful employment outcomes consistent with the individual’s goals. • Supported employment individual employment supports do not include volunteer work.  Such volunteer learning and training activities that prepare a person for entry into the paid workforce are addressed through pre-vocational services. • Supported employment individual employment supports do not include payment for supervision, training, support and adaptations typically available to other workers without disabilities filling similar positions in the business.   • Supported employment individual employment supports may be provided by a co-worker or other job site personnel provided that the services that are furnished are not part of the normal duties of the co-worker, supervisor or other personnel and these individuals meet the pertinent qualifications for the providers of service.  

 
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• Personal care/assistance may be a component part of supported employment individual employment supports, but may not comprise the entirety of the service. • Supported employment individual employment supports may include services and supports that assist the participant in achieving self-employment through the operation of a business; however, Medicaid funds may not be used to defray the expenses associated with starting up or operating a business. Assistance for self-employment may include: (a) aid to the individual in identifying potential business opportunities; (b) assistance in the development of a business plan, including potential sources of business financing and other assistance in including potential sources of business financing and other assistance in developing and launching a business; (c) identification of the supports that are necessary in order for the individual to operate the business; and (d) ongoing assistance, counseling and guidance once the business has been launched. • Individuals receiving supported employment individual employment supports services may also receive educational, pre-vocational and/or day habilitation services and career planning services. A participant’s person-centered services and supports plan may include two or more types of nonresidential habilitation services. However, different types of non-residential habilitation services may not be billed during the same period of time. • If States wish to cover “career planning” they may choose to include it as a component part of supported employment individualized employment support services or it may be broken out as a separate stand alone service definition.  • Supported employment individual employment supports may be furnished to any individual who requires and chooses them through a person-centered planning process. They are not limited to persons with intellectual or developmental disabilities.