Supportive Residential Services (SRS) for VR Customers
Discussion Paper
Background
Section 361.50 of the Vocational Rehabilitation (VR) regulations in 34 Code of Federal Regulations (CFR) requires states to develop and maintain written policies covering the nature and scope of each of the vocational rehabilitation services specified in 34 CFR §361.48. As appropriate to the VR needs of each individual and consistent with each individual’s individualized plan for employment (IPE), per 34 CFR §361.48(b), states must ensure that certain VR services are available to assist the individual in preparing for, securing, retaining, advancing in or regaining an employment outcome consistent with the individual’s strengths, resources, priorities, concerns, abilities, capabilities, interests, and informed choice. Under 34 CFR §361.48(b)(6), these required VR services include, in accordance with the definition in §361.5(c)(39), physical and mental restoration services, to the extent that financial support is not readily available from a source other than the designated State unit (such as through health insurance or a comparable service or benefit as defined in 34 CFR §361.5(c)(10)).
Supportive Residential Services assist customers who are in recovery to maintain stability, control, and abstinence from use of substances so they will be able to gain competitive integrated employment. This service is intended to provide a short-term supervised, stable living environment, with additional supports to assist the customer in pursuit of a successful competitive integrated employment outcome in a timely manner.
VR does not sponsor Supportive Residential Services until:
• after the customer has been determined eligible for VR services, and
• the service is included on the customer’s IPE or IPE amendment.
Issues
Staff identified the following issues that require clarification and revision to policy and standards:
1. Licensing requirements for facilities that provide Supportive Residential Services for Persons in Recovery (also referred to as substance abuse treatment facilities) for VR customers, currently allow for use of both licensed and unlicensed facilities. Thus, the quality of services received by VR customers varies greatly and the ability to ensure the safety and welfare of VR customers is limited.
2. Guidelines for decision making regarding the appropriateness of Supportive Residential Services for VR customers are not clearly associated with existing policy requirements for eligibility for VR services.
3. Limitations are not clearly defined to ensure that the provision of Supportive Residential Services does not include medical detox, which, in accordance with existing policy, is not a VR service.
4. Guidelines to ensure that customers participating in Supportive Residential Services are making definitive and timely progress towards an identified vocational outcome are not included in the required standards for providers.
Policy Recommendations
1. Standardize the quality of services and ensure the safety and welfare of VR customers by requiring that all facilities that provide Supportive Residential Services for Persons in Recovery for VR customers, are licensed as residential substance abuse treatment facilities by the Texas Department of Health and Human Services.
2. Ensure appropriateness of referrals by incorporating specific language into both policy and standards to ensure that the service is only provided to VR customers who have been determined eligible for VR services and have a current IPE that includes this service.
3. Reduce risk to agency and ensure compliance with policy by incorporating specific language that clearly states that Supportive Residential Services for Persons in Recovery does not include medical detox.
4. Ensure timely progress towards vocational outcomes by requiring that each customer have a specific Treatment Plan with the facility that clearly aligns with the customers Individualized Plan for Employment (IPE).
Rehabilitation Council of Texas Input
RCT reviewed the draft policy and procedures and recommended clarification of discharge planning requirements to ensure that customers were not discharged without advance notice to VR and, when applicable, caregivers. Clarifying language was added to both policy and standards.
DP Supportive Residential Services (SRS) for VR Customers
Agenda Item: 10/03/17 Commission Meeting 1