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e. Cooperative Agreements with Private Nonprofit Organizations

Describe the manner in which the designated State agency establishes cooperative agreements with private non-profit VR service providers.

Current Narrative:

IDVR does not establish cooperative agreements with private nonprofit vocational rehabilitation service providers. Services are purchased on a fee for service basis. IDVR does have cooperative agreements with several nonprofit CRPs for the coordination of services provided by Employment Networks for individuals who are Social Security beneficiaries who are Ticket holders. These cooperative agreements describe the coordination between both agencies.

IDVR maintains a Community Rehabilitation Providers (CRP) portal on the Division’s website.  The portal hosts communication relevant to CRPs and IDVR’s CRP Manual.  This Manual was first issued in January 2019 and incorporates significant input solicited from CRPs. The CRP Manual contains information on:

  • Service Billing Criteria and Process
  • Service Definitions
  • Overview of the On-Site CRP Monitoring Review and Corrective Action Process
  • Definition of Remote and Underserved Areas where IDVR supports travel due to lack of local services in identified areas
  • CRP Services Crosswalk to better align services under WIOA
  • Appendix information on the initial pilot for Customized Employment including rates and milestones for that pilot

The manual is intended to serve as a living document which will be updated over time, as needed, with input from CRP stakeholders.  A new version of the CRP Manual is tentatively slated to be released July 2020.  IDVR has already collected CRP comment in late 2019 for Manual improvements. Planned iterations of the guide include:

  • Examples of completed referrals/sample reports to promote quality referrals from VR staff and reports from CRP staff
  • Modified monitoring protocol to align with WIOA priorities
  • CRP onboarding requirements (accreditation, insurance, and prerequisites to ensure a baseline of quality and accountability)
  • Updated fee schedule to better align service compensation and service complexity

CRPs provide specific services for customers based on a fee-for-service or through a specific invitation to bid on a Request for Proposal (RFP). Idaho CRPs must be accredited by either the Commission on Accreditation of Rehabilitation Facilities (CARF) or the Rehabilitation Services Accreditation System (RSAS), follow the process and procedures mentioned in this manual, and undergo periodic monitoring by IDVR to continue a working relationship with the Division. This manual addresses the Idaho Division of Vocational Rehabilitation’s state-federal program.  The CRP Manual outlines the service billing criteria and process required before the Division will process bills, including prohibitions on billing for multiple customers unless group services are authorized.  Group service rates differ from individual service rates and are outlined in IDVR’s Fee Schedule.  Furthermore, day rates are published for non-community-based assessment where no other options are available in the community.  This section also mandates notification in the eventuality of anticipated service discontinuation and prohibits customer abandonment (instead requiring at least 30 days notification for a soft handoff to another CRP ahead of CRP closure in a region).  A dispute resolution process including an escalation chain is also established in this section of the guide.

IDVR identifies allowable services under Section Two of the CRP Manual: CRP Service Definitions.  Service outlined in this section include the major headings of assessment, job related supports (job search activities, short-term job supports, job readiness training), Pre-ETS (required activities under 34 CFR 361.48(a)(2)), and Supported Employment.  Additionally, requirements to document fading and/or skill acquisition for the continue of SE hours are articulated in this section.  IDVR is working with CRPs to strengthen understanding of documented progress toward SE stability, and CRPs have requested additional guidance in this area.  The Division will issue improved guidance in the tentative July 2020 release of the Manual.  Slated improvements include increased guidance on specific services with a potential incorporation of the agency’s benefits planning initiative.  The manual covers documentation of stability and transition to extended support and outlines the Youth Extended Services option to provide this service to qualifying youth where no alternate funds for extended support are available. 

IDVR is in the process of evaluating the CRP fee schedule for allowable costs using:

  • WINTAC’s “Review of Vocational Rehabilitation Agency Rates, Methodology, & Monitoring of Performance for Purchased Service” which includes
    • An evaluation of rates for similar services paid by other SVRAs
    • Federal cost principles at 2 CFR 200.405(a) to align costs to relative benefit
    • Accreditation requirements
    • Payment methods (fee-for-service, performance, contracts)
    • Reporting requirements
    • Monitoring

The Division’s 2020 modification of the guide will apply each of these considerations to inform potential fee updates: While the Division’s current CRP Manual (January 2019) does address each requirement, the Division’s analysis may incorporate innovative practices used by other SVRAs.  Currently the Division does not separate rate by complexity of rehabilitation needs but is seeking to remedy this deficiency.  The Division is enlisting the assistance of the Idaho Division of Purchasing to inform the analysis of service rates.  Novel rates for Customized Employment and Benefits Planning are expected outcomes of this process, in addition to a reconsideration of the agencies total fee schedule.

Pre-employment Transition Services (Pre-ETS) agreements including rates are established under a separate process.  In areas where volume is sufficient, the Division employs bids/contracts.  The majority of contracts are filled in regional population centers, however when an area has no contract (rural and remote Idaho), or all slots are filled for a contracted group, the Division employs individual Pre-ETS provision at existing hourly rates to ensure the availability of Pre-ETS,

IDVR issues an annual report of CRP performance, the Community Rehabilitation Partner Employment Report (CRP-R) process which produces the following elements by CRP and region:

  • Number of CRP Provided Employment Services
  • Employment Outcomes with CRP involvement in closure
  • Average Hourly Wage of placements
  • Average Hours Worked
  • Average Annual Earnings
  • Percentage of Employer Sponsored Benefits
  • OES employment outcomes by category
  • Primary impairments served by percentage of total served
  • Percentage served within age strata

The CRP-R is disseminated to CRPs annually and used by VR staff to assist with informed choice of CRP when selecting a provider for planned services.