Many if not most providers of employment under special wage certificates are also responsible for providing support services and case management related to employment for such individuals. In the view of APSE, such a relationship is a clear conflict of interest i.e., the employer of the individual is also the entity responsible for assisting – them with transitioning into competitive integrated employment and serves in a case management role. These roles should be separate. (Note: The Center for Medicare and Medicaid Services now requires that case management for individuals receiving services under a Medicaid waiver must be conflict-free i.e., the same entity cannot be providing – case management and services and supports.) Given that a large number of individuals being paid under 14(c) certificates receive Medicaid funded supports, APSE feels that the certification of employers under 14(c) should reflect this requirement.) Adding questions that identify the source of employment and other supports for the worker will assist in identifying the extent of this issue. We request the following questions: Is the employer provided funding to provide case management services for the worker? Is the employer provided funding to assist the individual to transition to competitive integrated employment? If so, what are the sources of this funding? - State/ county intellectual developmental disability agency; - State/county mental health agency; - Other APSE requests that the birth date for each individual be requested. This will not only help ensure that the requirements for youth 24 under Section 511 of WIOA are complied with, but will also provide important demographic data on the use of special wage certificates to guide federal policy. In terms of (d) worker provided reasonable accommodation(s)?”. The purpose of “Was this information is not clear, and given the subjective nature of reasonable accommodations, we feel this would provide little value. Either additional specific information on the reasonable accommodations being provided should be requested, or this question should be removed APSE strongly feels that our requested changes and additions to the information requirements for special wage certificates are not unduly burdensome, and are absolutely necessary as part of efforts for consistent federal policies on employment of people with disabilities, ensuring that citizens with disabilities, including those with the most significant disabilities, are given every opportunity to achieve competitive integrated employment, and not unnecessarily segregated in violation of federal law and policy. Thank you for your full consideration of our comments. Sincerely, Allison Wohl Executive Director, APSE
Many if not most providers of employment under special wage certificates are also responsible for providing support services and case management related to employment for such individuals. In the view of APSE, such a relationship is a clear conflict of interest – i.e., the employer of the individual is also the entity responsible for assisting them with transitioning into competitive integrated employment and serves in a case management role. These roles should be separate. (Note: The Center for Medicare and Medicaid Services now requires that case management for individuals receiving services under a Medicaid waiver must be conflict-free – i.e., the same entity cannot be providing case management and services and supports.) Given that a large number of individuals being paid under 14(c) certificates receive Medicaid funded supports, APSE feels that the certification of employers under 14(c) should reflect this requirement.) Adding questions that identify the source of employment and other supports for the worker will assist in identifying the extent of this issue. We request the following questions: Is the employer provided funding to provide case management services for the worker? Is the employer provided funding to assist the individual to transition to competitive integrated employment? If so, what are the sources of this funding? - State/ county intellectual developmental disability agency; - State/county mental health agency; - Other APSE requests that the birth date for each individual be requested. This will not only help ensure that the requirements for youth 24 under Section 511 of WIOA are complied with, but will also provide important demographic data on the use of special wage certificates to guide federal policy. In terms of (d) “Was worker provided reasonable accommodation(s)?”. The purpose of this information is not clear, and given the subjective nature of reasonable accommodations, we feel this would provide little value. Either additional specific information on the reasonable accommodations being provided should be requested, or this question should be removed APSE strongly feels that our requested changes and additions to the information requirements for special wage certificates are not unduly burdensome, and are absolutely necessary as part of efforts for consistent federal policies on employment of people with disabilities, ensuring that citizens with disabilities, including those with the most significant disabilities, are given every opportunity to achieve competitive integrated employment, and not unnecessarily segregated in violation of federal law and policy. Thank you for your full consideration of our comments. Sincerely, Allison Wohl Executive Director, APSE
APSE-14C-Information-Collection-Comments-Oct15.docx