Policy Summary Wisconsin: Integration of Customized Employment into Vocational Rehabilitation and Medicaid-Funded Services
1. Summary of the Policy
Wisconsin has implemented policy changes for two state level agencies to allow a full range of Customized Employment (CE) services to be provided to consumers. The Department of Workforce Development's Division of Vocational Rehabilitation (DVR) and the Department of Health Services' (DHS) Medicaid 1915(c) Home and Community-Based Services (HCBS) waiver programs both allow funding for CE services as a type of Supported Employment.
- Within the Wisconsin VR system, individuals with disabilities who meet certain criteria are provided information about the use of CE strategies and the availability of those services locally. If the consumer chooses CE, the DVR counselor and the consumer negotiate an Individual Plan for Employment (IPE) with an integrated customized job as the employment goal.
- During the recent renewal of the state's Medicaid 1915(c) HCBS waivers for long-term care, Wisconsin DHS revised its definition of Supported Employment (SE) to include CE services as allowable expenses. Medicaid waiver eligible individuals who establish an employment goal are referred to DVR for Supported Employment and CE employment-related services.
DVR CE services involve the entire set of strategies recommended by the U. S. Department of Labor's Office of Disability Employment Policy (ODEP) (i.e. Discovery, Vocational Profile; CE Plan; Visual Resume; Job Negotiation or Customization; Customized Self-Employment; On-the-Job Support). They are ordered in a way that ensures each distinct CE service builds upon the knowledge and insights gained through prior CE services. The intent is to develop an integrated customized position that is valuable to the business and suited to the individual's interests, skills, and conditions for successful employment.
Wisconsin DVR also made the decision to make CE services (particularly Customized Job Development involving employer negotiation) available to VR consumers who are not eligible for SE. The availability of these CE services is expected to facilitate successful employment outcomes for many VR consumers who do not need SE services, or who could avoid the need for SE services with up-front customization of their employment.
2. What is the function of the policy that promotes the principles of Customized Employment?
Wisconsin's CE policy is designed to provide an evidence-based alternative strategy for customers with significant disabilities to achieve integrated customized employment at good wages or profitable self-employment.
3. Where is the policy housed?
The policy is housed within both the Department of Workforce Development, Division of Vocational Rehabilitation and Department of Health Services, Division of Long Term Care, Bureau of Long-Term Support (Family Care/Family Care Partnership and Program of All-Inclusive Care for the Elderly (PACE) programs. )
4. Whom does it impact?
The policy impacts customers of these two systems who have significant disabilities, such as Intellectual/developmental or physical disabilities, who have been unable to find or maintain jobs acquired through standard SE or other, traditional, workforce development programs.
5. What have been the costs?
Within both the Wisconsin Medicaid HCBS waiver program and the VR system, CE offers a cost-neutral method for matching an individual's skills with an employer's unmet needs. Cost neutrality is achieved by pricing CE services at rates that are similar to reimbursement rates for traditional SE services. To receive authorizations from DVR to provide CE services, provider staff delivering the services must have completed CE training provided by a nationally recognized CE expert.
6. How sustainable is the funding?
Funding is sustainable because the CE option is integrated into the VR system and funded from the same budget as other DVR services
7. How has the policy been implemented?
DVR and DHS conducted a pilot in 2010, after which they implemented CE statewide. A description of the pilot and how it was conducted is in an attachment. The attachment also contains a full description of the CE process and several forms used to record the activities of each step of the CE model.
In July, 2011, DVR established Customized Employment as a fundable alternate model of Supported Employment. Criteria for determining an individual's eligibility for receiving CE services, the CE process, a CE fee schedule and a list of qualified providers can be accessed on the Supported Employment page of the DVR Web site. (See link below.) A service provider must have staff members who have received a certificate of completion for a course of training on CE methods, conducted by a nationally recognized expert on CE, to be eligible for payment from DVR. To facilitate the implementation of the CE model, DVR funded the trainings of provider agency staff members for one year at no cost to the providers. The training course consisted of individual modules for each step of the model. Trainings on different stages of the CE process were intentionally staggered. Training participants were given the chance to go into the field after each training session, put what they learned into practice, and come back to the next training with questions, challenges, or roadblocks they encountered. A certificate is given to each staff member who completes the course. More than 250 provider staff members have received certificates.
DVR also added information about CE to its Coding Definitions and Supported Employment glossary. Supported Employment guidance for DVR staff contains a definition of CE, including Customized Self-Employment, and a notation to consider Customized Employment during Supported Employment assessment and IPE development.
A DVR toolkit for Customized Self-Employment contains the agency's self-employment policy, a comprehensive discussion of the required steps in the process of starting a business, and information about outside factors, such as Social Security benefits and credit. Three self employment models are presented, two in the toolkit and one in a standalone document:
1) basic self-employment, 2) a Business-Within-a-Business model, and 3) a Resource Ownership model.
DHS included CE services as allowable expenses in its 1915(c) HCBS waiver application to the Federal Centers on Medicare and Medicaid. Wisconsin waiver services are provided through the Family Care, Family Care Partnership and PACE programs. DHS contracts with Managed Care Organizations (MCOs) for delivery of all Medicaid services, including health care and employment. MCO members who establish employment goals are referred to DVR for employment-related services, including the development of an IPE. The MCO continues to provide non-employment related services to its members. MCO staff members received the same Customized Employment training as DVR provider staff.
8. What were the challenges in implementing the policy?
One notable challenge is the need to ensure providers' fidelity to the Customized Employment model. Care was taken to ensure that the exact definition and terminology of CE has been maintained in the policy and its implementation documents. This challenge is seen as crucial to ensuring the quality and success of the model. The certification of provider staff support necessary consistency in service delivery by all providers and agencies.
9. What were the successes in implementing the policy?
The measure is budget-neutral by design, which has made it much easier for agencies purchasing services to embrace and formally offer CE. Certification of CE training ensures conformance to the CE model.
10. What are some recommendations for other systems?
- Maintain fidelity to service quality and efficacy. Wisconsin DVR published technical specifications specific to CE to ensure the quality of the services, but training and certification of VR counselors and MCO staff is critical for ensuring that service specifications and standards are adhered to in practice.
- Be patient and persistent. Having been in the process of putting CE in place since 2007, our respondent advised that it takes time for CE to adequately take root in the culture of service providers and among VR staff.
11. Copy of Policy
DIVISION OF VOCATIONAL REHABILITATION
The DVR Web site lists the criteria for establishing an individual's eligibility for CE services.
State of Wisconsin Department of Health Services
2014 Family Care Programs Contract, January 1, 2014 - December 31, 2014
Addendum X. Benefit Package Service Definitions
- Home and Community Based Waiver Services
8. Habilitation Services
(e) Supported Employment
for information on Customized Employment and Customized Self-Employment services.
12. Supporting Documents
Technical Assistance Guide For Adults Seeking Integrated Employment In Support of Interagency Agreement
A guide for an interagency agreement between DVR and DHS's Family Care/Family Care Partnership and PACE programs and the DHS self-directed long term supports program. The guide details the roles of the job seeker, DVR counselor, MCO staff, parents and others in helping the job seeker achieve his or her employment goal. The guide describes the process for referring participants to DVR for employment-related services. Question #21 on page 39 directly addresses CE.
Division of Vocational Rehabilitation and DHS Division of Long Term Care Memorandum of Understanding
The MOU clarifies the roles and funding responsibilities of the agencies in regard to common customers.
Information about CE process, fees, and list of approved CE providers within the VR system are available at the DVR Web site.
DVR created a pilot in 2010 to test the impact of customized strategies. Attachment #1 describes this pilot and the customized process used. It also contains forms for recording CE activities.
DVR Coding Definitions Manual
Codes necessary to meet reporting requirements of the Rehabilitation Services Administration.
DO19 SE: CE Services pg. 14
Supported Employment Glossary of Terms
Includes Customized Employment, Discovery and Customized Self-Employment.
Guidance to DVR Staff on Supported Employment / Long Term Support
Pg. 4 Customized Employment Definition: Includes Customized Self-Employment and has link to CE page on DVR Web site.
Pg. 5 Determination Of Need for Supported Employment: Contains a statement that alternate models of SE, including CE, should be considered when developing an Individual Plan for Employment. Has link to SE page on DVR Web site, with CE
The Customized Self-Employment Toolkit describes the process for implementation of this service: including a business-within-a-business model. Appendix 7
Resource Ownership Guidance Piece
A form of Customized Employment
13. Contact Information
Lisa A. Mills, PhD
Consultant on Employment Policy and Systems Change
Wisconsin Department of Health Services
2707 Mason Street
Madison, WI 53705
Phone: (608) 225-4326