PURPOSE: To provide a summary of information to consider before the purchase of goods/services are made for a client. See Chapters referenced for additional details and information.

GUIDING PRINCIPLES

Informed Choice: Vocational Rehabilitation staff are responsible for assisting persons with disabilities in making informed choices about their services, service providers, procurement methods, reason for any “sole source” determinations while ensuring consistency with Nebraska VR's policy and procedures. Informed Choice is a flexible, ever moving process, empowering an individual to consider a range of options towards self-determination. In the end, both the individual and the specialist hold responsibility for the decisions made and for the outcome of those decisions. 

Accountability: VR has a responsibility to ensure state and federal funds used for case services are spent appropriately. Specialists must inform clients of the policies surrounding the use of cash advances and provider authorizations for purchases of goods and services and the clients of the consequences of misusing funds. Clients must be held accountable for using the cash advance and/or provider authorizations to purchase what is authorized and agreed upon in their rehabilitation plan.

Comparable Services and Existing Benefits: 

Rule 72 - 003.01. Program services and funds may supplement, but not supplant, those services and benefits available to a recipient and his or her family from any outside agency or entity. If comparable services and benefits are currently available and ready for immediate use, they must be used to meet, in whole or part, the cost of program services.

Rule 72 – 003.02. If any public entity other is obligated under Federal or State law to provide or pay for any services considered to be vocational rehabilitation services, than VR funds cannot be used to provide or pay for such services.

Rule 72 - 003.03. Applicants for and recipients of services must apply for and accept any existing comparable services or benefits to meet, in whole or part, the costs of required and necessary services. Comparable services and benefits are provided or paid for, in whole or in part, by other Federal, State, or local public agencies, by health insurance, or by employee benefits. 

Rule 72 - 003.04. The requirement to determine the availability of comparable services and benefit does not apply if this would interrupt or delay –

• The provision of vocational rehabilitation services to any individual who is determined to be at extreme medical risk, based on medical evidence provided by an appropriate qualified medical professional.
• An immediate job placement; or
• The progress of the individual for more than thirty (30) days toward achieving the employment outcome identified in the individualized plan for employment.

Client Contribution: Individuals will not be asked to participate in the cost of any service necessary for determining their eligibility for the program or assessment for determination of vocational rehabilitation needs. 

• SSI/SSDI recipients- are exempt from contribution to the cost of IPE goods or services unless the amount exceeds the least cost option. If the client does not choose the lease cost option, they are responsible for the increased cost. EXCEPTION: After a search for comparable services and existing benefits, VR will grant an exception to the fee schedule for the remaining cost of the good or services. 
• Non-SSI/SSDI recipients- Clients will not be asked to contribute to the cost of IPE goods or services unless the cost exceeds Rule 72 (cost containment guidelines), or they are choosing a more costly option. If the client does not choose the least cost option, the client is responsible for the increased cost. EXCEPTION to Rule 72 may be considered, after an exploration of comparable services and benefits, loans, and client contribution. If there is no alternative to addressing the needed good or service, VR may make an exception and fund the remaining amount. 
• For further information see Program Manual Exceptions and Approvals

Procurement Standards:

• An authorization gives the provider the authority to supply goods or services to a client/recipient.
• Authorization of a good/service requires a determination of its necessity for eligibility, assessment, or participation in the IPE. 
• Vocational Rehabilitation has a responsibility to ensure that state and federal funds used for case services are spent appropriately, and informing the client of the policies surrounding the use of cash advances and provider authorizations for purchases of goods and services.
• A thorough search for comparable services and benefits to meet, in whole or part, the costs of required and necessary services must be completed, and all clients are required to apply for and use comparable services and benefits.  
• All goods/services must be authorized in QE2 prior to the good or service being provided, and meet the requirements in Rule 72;
  • Verbal authorization is permitted but does NOT negate the requirement that the authorization be completed in QE2 prior to the goods/service being provided; 
  • Authorizations completed after goods/services begin could be determined an audit exception and require the use of state funds for the cost of those goods and services. Using state funds for audit exceptions reduces the amount of state funds available for federal match;
• Prepaid cards such as gift cards or gas cards cannot be purchased and given to a client for use in purchasing goods or services.
• All purchases are exempt from state and local sales tax. If requested, send to the provider a Nebraska Resale or Exempt Sale Certificate (Form 13).
• Considering all available alternatives, Vocational Rehabilitation will procure the least cost option for VR specified services, goods and supports, which meet the needs of the individual and provide adequate quality and available serviceability.
• Cost estimates are required for services, goods and supports that are not subject to an established fee or specified amount in Rule 72. All cost estimates must be documented in the case service record. 
• Exceptions and Approvals Policy. Exceptions and Approvals
  • Goods and services in excess of $2,000 and not part of the fee schedule require Office Director approval. VR Certificate Programs and Project Search Worksite Skills Trainer are exempt from this approval. 
  • Document "sole source" determinations. When only one vender is available, this reason needs documented to justify why the required bids were not obtained. 
  • Exceptions to the fee schedule. If the VR Specialist determines the necessary goods and/or services cannot be provided without exceeding the Fee Schedule, all financing available from grants, loans, personal or family resources (including client contribution), and other resources, to offset a part or all of the excess costs for necessary goods and/or services must be explored No exceptions can be made to how VR will pay. 
• Mileage more than 25 miles round trip can be paid to a provider, if requested, at the current NDE mileage rate for travel from the provider’s primary work location to the service delivery site. Invoice must include the “to” and “from” travel destinations.
• Government procurement standards require the involvement of at least two people in the procurement and payment process. Those authorizing or approving payment for services, goods, or supports, should not also process payments, or assume accounting responsibility for payment of those same services, goods, or supports.
• Goods and services should be procured from Nebraska service providers and businesses to the maximum extent possible.
• Vocational Rehabilitation funds cannot be used, either directly or indirectly, for the purchase of any land, the purchase or erection of any building, entertainment expenses, alcoholic beverages, tobacco products, firearms, or ammunition products.

1. Prior to purchase the VR Specialist is responsible to:​​​

• Determine the good/service is necessary for eligibility, assessment, or participation in the IPE.
• Determine if there are other reasonable options available to address the need.
• Complete a thorough search for comparable services and existing benefits (employer, college, health & home insurance, Medicaid/Medicare, etc.) to meet, in whole or part, the costs of required and necessary services; all clients are required to apply for and use comparable services and existing benefits. For further information, see Program Manual Comparable Services
• Determine least cost option which meet the needs of the individual and provide adequate quality and available serviceability.  
• Determine need for discussion with client, as applicable on: 
  • Exceptions and Approvals If the cost will exceed the cost containment guidelines (Rule 72), discuss financing available from grants, loans, personal or family resources including client contribution, and other resources, to offset a part or all the cost of necessary goods and/or services.
  • Client Contribution 
  •  Vested Interest and Equipment Issuance and Recoupment
• Provide Task note documentation of the purchase justification to cover the topics above. See Program Manual Documentation
• The authorization must be completed in QE2 prior to the time the goods or services are provided. For further guidance, see #4 below and the forms attached to this chapter (IPE Services, IPE Assessment Services, and IPE Assessment Supports)

2. Determine the cost of a service, good or support in one of two ways:

Fee: A rate or amount established in a written agreement or fee schedule

Cost: Actual cost of the services, goods or supports based on a cost estimate or a predetermined fixed amount for certain designated services and supports.

Cost Estimates. Cost estimates are required for services, goods and supports that are not subject to an established fee or specified amount in Rule 72.  A cost estimate is the proposed cost of a service, good, or support obtained by comparison shopping, use of governmental or educational price lists, internet, phone, or other method by which the cost can be determined. Cost estimates may be for similar, but slightly differing, goods or services, as long as all bids meet the client's needs. 

• All cost estimates must be documented with a hard copy from the source and uploaded into the case file, except for cost estimates obtained by phone with no written confirmation available from the vender, which must be noted in a task entry. At a minimum, documentation must include provider name, method of obtaining and rate and unit of service (when applicable).
• The client’s word cannot be the source of the documentation (e.g., “client reports rent is $445.00 per month”) for a cost estimate. If the information for the cost estimate is given by the client, the documentation requirements above still apply. 
• VR will select the bid by using a combination of the following criteria: (detailed task entry required):
  • Timeliness and availability of the provider to provide the goods or services​.
  • The past performance of service providers to achieve quality outcomes for clients, 
  • The qualifications of professional and technical service providers, 
  • The available product serviceability, and prior product satisfaction, and
  • The lowest cost that meets the individual's needs,

Cost estimates are required if:

• The method of payment is cash advance. One (1) documented cost estimate required.
• The service, good, or support is $2,000 and above:
  • Two (2) documented estimates must be obtained for individual items $2,000 - $4,999.99. 
  • Three (3) documented estimates must be obtained for individual items $5,000 and above. 
  • A cost estimate from a single provider may be used if a service, good, or support is available only from a sole source or sole distributor. The identification of the provider as a sole source must be documented in the task notes.

3. Purchase in one of three ways. Appendix B of Rule 72 defines which method(s) can be used for which services, goods, and supports.

Cash Advance. An amount based on a cost estimate, issued to the recipient in advance of the purchase of services, goods and supports.

VR staff are responsible to:

• Review with the client the Service Authorization identifying the services, goods or supports allowed to be purchased with the cash advance, and the Authorization Instructions. Both the Service Authorization and the Authorization Instructions must be given to or mailed to the client.
• Inform the client that proof of purchase to verify the purchase was completed as authorized is required. Failure to provide proof of purchase may result in denial of future cash advance payments to that client. See Program Manual Client Accountability for corrective action for misused funds. 
• Ensure proof of purchase documentation is received and noted in hard copy in the case file and in a task entry. Preferred proof of purchase documentation includes, but is not limited to; receipts, invoices indicating payment, internet confirmations, credit card statements, cancelled checks, or visual verification by VR staff. If no documentation is available, a Proof of Purchase form can be utilized. Purchase documentation must show provider name, date of purchase, detail of purchase, and cost of good or service. Upload documentation to the casefile. 

Reimbursement. Payment to a recipient for pre-authorized services, goods or supports upon the rendering of recipient’s paid or credited receipts or printed online confirmation copy.

VR staff are responsible to:

• Review with the client the authorization identifying the services, goods or supports allowed to be purchased. Both the Service Authorization and the Authorization Instructions must be given to or mailed to the client.
• Inform the client they must provide proof of purchase documentation (e.g. receipt, invoice indicating payment, internet confirmation, credit card statement, cancelled check, etc.) in order to be reimbursed.
• Ensure proof of purchase documentation shows provider name, date of purchase, detail of purchase, and cost of good or service.
• Obtaining a completed and client's signed reimbursement form with the proof of purchase documentation.

Program Purchase. Payment directly to the provider for a pre-authorized amount for purchase of services, goods, or supports upon completion of the service or receipt of the goods.

VR staff must:

• Ensure the provider is willing to accept an authorization from VR and invoice VR for the good, service, or support.
• Review the Service Authorization with the client and identifying the services, goods or supports allowed to be purchased from the provider with the authorization, and the Authorization Instructions. Both the Service Authorization and the Authorization Instructions must be given to or mailed to the client.
• Ensure the authorization identifies the specific service(s), good(s), or support(s) must be sent to the provider.
• Ensure the good or service was provided as authorized. 

4. Authorization.

Complete the authorization in QE2 prior to the goods or services being provided; the authorization must identify:

• the terms and conditions of providing the goods or service,
• the dates the provider is authorized to supply the good or services,
• a description of the goods or services being authorized, and
• the amount to be paid based on VR’s cost containment guidelines, except for goods/services authorized at Medicaid rates.
  • For services with required standard text, the standard text is required on the authorization.
  • The authorization must be sent to the provider prior to providing the goods or services so they are aware of the authorization conditions.

           If an authorization is not completed in QE2 prior to the good or service being provided (start date of authorization is prior to the day the authorization is completed), approval is required by the Office Director/Program Director:

           A. Complete the authorization in QE2;

           B. Enter the "Reason service started prior to today" text box; include the name of the specialist who requested the authorization and the reason the authorizaiton is being completed after the start date of the good/service; reason indicating failure to plan ahead and authorize will be an audit exception.

           C. Authorization will be submitted to the Authorization Approval screen and an auto generated email sent to the Office Director/Program Director notifying them an approval is needed;

           D. Office Director/Program Director will enter the justification for Approving or Denying the authorization;

           E. Upon approval/denial of the authoriation, an auto generated email will notify staff who created the authorization;

           F. A task note will be auto generated with the reason and the approval/denial of the Office Director/Program Director.

Extensions:

• The end date on an authorization may be extended to allow for services to be provided or goods received later than originally authorized.
• A reason for extending the authorization date is required.
• Authorization extensions cannot increase the amount of the authorization or the service.
• A copy of the authorization with the revised end date must be printed and sent to the provider.

Replacement Authorization. Replacement authorizations should not be done to pay more than the amount originally authorized. If a replacement authorization is done for a legitimate reason (i.e., change providers) it will not be considered an audit exception.

Add Encumber. Payment against an authorization can exceed the amount authorized for the following:

• Shipping/freight
• Tax (if from another state)
• Authorization amount was in error and provider contacted VR (document in task note)
• Adjustments made to authorizations completed in different fiscal years (e.g. Project Search)
• An invoice is received for more than the amount authorized for a reason other than those mentioned above, and meets the requirements of the Consumer Accountability Policy

Closing the case in QE2: The case cannot be closed until all authorization end dates have been reached, unless the authorization(s) have been paid in full. This includes authorizations that have a $0 balance because of an unencumbrance. 

IPE Services

Assessment Services

Assessment Supports