4/7/20 - Message for Division of Rehabilitation Services Providers - Summary of Actions to be Implemented to Assist Community Providers of Vocational Rehabilitation and Supported Employment Services

Helping Families. Supporting Communities. Empowering Individuals.

4/7/2020

Tuesday, April 7th, 2020


Division of Rehabilitation Services

Updated as of 4/3/2020

Summary of Actions to be Implemented to Assist Community Providers of Vocational Rehabilitation and Supported Employment Services


General Overview:

  • The DRS participated in a nationwide call on March 30th, 2020 with Mark Schultz, Acting Assistant Secretary for the Office of Special Education and Rehabilitative Services (OSERS) and David Steele, Fiscal Unit Chief of the Rehabilitation Services Administration (RSA).
    • At present, the RSA does not have the authority to offer any flexibility within their current authority. Specifically:
      • Payments for services that are not rendered are unallowable;
      • Retainer fees are unallowable;
      • Extensions to the period of performance are unallowable;
      • Maintenance of Effort and non-federal matching requirements cannot be waived; and
      • The 15% federal reserve requirement for Pre-employment Transition Services cannot be waived
  • The RSA is in the process of offering written guidance reinforcing their current authority.
  • The Coronavirus Aid, Relief, and Economic Security (CARES) Act signed into law on March 27th, 2020 requires the Secretary of OSERS to provide a report to Congress within 30 days of enactment recommending any additional waivers and flexibilities necessary to be enacted.
    • Comments received from state VR agencies and other stakeholders will be considered as OSERS develops recommendations.
  • The DRS has actively sought support for leniency and relief directly from the OSERS and from the States Congressional delegation.


Community Provider Contract Changes (does not include STEP & TS Contracts):

  • Due to the limitations of what can be funded through VR and SE services, the DHS has secured one-time non-federal funding to offset lost revenue.
    • Formal contract amendments will be required to include the new funding source and additional payment language to the existing contract.
      • Signed two party agreements and certifications and disclosures will be required in order to receive a lost revenue payment.
      • Group bills for services performed consistent with the contract must be submitted and acted upon timely.
      • Lost revenue payments will be offset by performance payments.
  • The following language will be added to the pricing section of each affected contract:


Consistent with the Illinois Department of Human Services COVID and Administrative Burden Relief Policy and Procedures, the Division of Rehabilitation Services has been allocated non-federal one-time funding to assist with lost revenue. Lost revenue is based on the most recent six (6) months earnings funded by IDHS-DRS for the contract. Lost revenue payments will be offset by any earned performance-based payments. Acceptance of the lost revenue payment(s) requires the community provider to:

  1. Payroll: Pay all current employees their full pay and benefits.
  2. Tax and Fringe: Remit all employer employee contributions such as payroll taxes, employment security, FICA, insurance, retirement plans. This is not an all-inclusive list.
  3. Pay all fixed costs necessary to allow for immediate return to full-service delivery when allowed
  4. If continuing to perform services on a limited basis, submit billings for services provided under current processes.
  5. Submit their quarterly IDES Form UI-3/40 to corroborate their personnel costs to the program 90 days after filing with IDES.

Item #5 must be submitted to your DRS Project Officer 90 days after filing with IDES. Failure to provide item #5 will result in a payment hold until the documentation is submitted.


Time limited loss of revenue payments are predicated on the availability of revenue, and the duration of COVID-19, and any future requirements set forth by the Department regarding other federal and state loan programs.


New Revenue Opportunities for All Community Providers (excludes Uniform Grant Agreements):

  • The DRS will launch a COVID-19 Customer Status Report to be used by Community Providers to engage customers. This is a time limited opportunity.
  • Community Providers will have an opportunity to earn $50 per week per customer.
  • COVID-19 Status Reports and Group Billing Sheets are required to be submitted to the DRS Project Officer the Monday following the week of services.
  • Information collected by Community Providers will be shared with the field for entry into WebCM and subsequent follow-up as needed.


Resources for Community Providers:

http://www.dhs.state.il.us/page.aspx?item=123118

http://www.wintac.org/

https://www.transitionta.org/

nationaldeafcenter.org/covid19

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