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Client Contribution and Comparable Services

Status: Archived

Approved Date: November 08, 2019

All individuals will be asked and are expected to help pay for the costs of services received by seeking out, applying for, and using any comparable services and benefits for which they are eligible and keep regular contact with program staff regarding case progression, including promptly informing staff of changes in their personal financial circumstances, and of problems encountered with services or service providers. 

Participation by the individual in the cost of services, goods or supports is voluntary and can lead to increased ownership by the client in his/her rehabilitation plan. It also results in savings in VR funds allowing more individuals with disabilities to be served.

  1. As services are identified, VR staff  must have a conversation about the cost of the service and how they will be funded. Vocational Rehabilitation has a responsibility to ensure that state and federal funds used for case services are spent appropriately and as identified on the rehabilitation plan. The discussion about the cost of services needs to include the following: 
    • Comparable Services:  VR staff must seek out and utilize all comparable services and 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. Clients are required to apply for and use comparable benefits. 
      • Program services and funds may supplement, but not supplant, those services and benefits available to a client and his or her family from anther outside agency or entity. 
      • If any public entity other than the program is obligated under Federal or State law or assigned responsibility under State policy, to provide or pay for any services that are also considered to be vocational rehabilitation services, then VR funds cannot be used to provide or pay for such services. 
      • Applicants for and recipients of services must apply for and accept any existing comparable service or benefit. Program funds cannot be used to replace comparable services and benefits a recipient is eligible for, but refuses to apply or accept.
    • Least Cost Option. Considering all available alternatives including those services which can be provided directly by program staff without additional cost to the program, the program will procure the least expensive, comparable services, goods and supports which meet the recipient's needs. 
    • Cost Estimates.  Cost estimates are required for services, goods and supports that are not subject to a set fee or specific amount in Rule 72. (See High Cost approval for specifications).
    • Client Contribution: All individuals will be asked if they are willing and able to participate in the cost prior to authorizing VR funds. Services exempt from client contribution: 
      • service necessary for determining their eligibility for the program
      • assessment for determination of vocational rehabilitation needs
      • post-secondary training allowance 
    • Informed Choice: Client's may choose higher priced services, goods, supports and/or service provider(s), but will also be responsible to pay for the excess cost incurred. 
    • Review of Rule 72 Cost Sharing and Cost Containment Rules: This discussion should be a brief summary of how VR is funded by state and federal dollars and to be accountable with these funds, VR must seek out comparable services and supports, operate within cost sharing and cost containment rules, as well as request client contribution. Consider each item to be funded and discuss the associated fee schedule cap (Appendix B or Rule 72). If the service, good or support is higher than the fee schedule, discuss how this difference can be funded (comparable services, friends, family, loans and/or client contribution). 
    • Client Accountability:  Clients must be held accountable for using the cash advance and/or vendor authorizations to purchase what is authorized and agreed upon in their rehabilitation plan. Vocational Rehabilitation staff are responsible to inform clients of the policies surrounding the use of cash advances and vendor authorizations for purchases of goods and services and verifying/documenting the purchase of the goods and/or services authorized (See VRIS Case Service Procurement Policy). Vocational Rehabilitation Specialists are responsible for informing the consumer of the consequences of misusing funds. The misuse of funds occurs when a consumer:
      • will not provide documentation, as defined in the Case Service Procurement Policy, verifying what was purchased;
      • uses a cash advance for something other than what was authorized; or
      • purchases something from a vendor other than what was authorized.
  2. Document in the task note the justification and rationale for the agreement and choice of services, goods or supports. Include the cost estimates and amount of contribution/benefits to be used for client contribution, comparable benefits and services. 
  3. If it has been determined there are not adequate benefits, services and/or client contribution to fund the additional cost above the Rule 72 Cost Containment and Cost Sharing fee schedule, VR staff can request a cost exception to Rule 72. (See Rule 72 Cost Exceptions chapter in VRIS).

Client contribution  

All individuals will be asked if they are willing and able to participate in the cost prior to authorizing VR funds for any other service.

Participating in the cost of services is voluntary, can lead to increased ownership by the client in his/her rehabilitation plan. It also results in savings in VR funds allowing more individuals with disabilities to be served.

Individuals will not be asked to participate in the cost of:

  • service necessary for determining their eligibility for the program
  • assessment for determination of vocational rehabilitation needs
  • post-secondary training allowance described in the chapter on post-secondary training.

Under no circumstances are VR staff to accept from the client any cash, check or other financial instrument. Instead, a local office staff member is to provide the client with a stamped envelope, pre-addressed to the State Office (Attn: Cathy Callaway). The client is responsible for preparing and mailing his/her check, money order, or any other financial instrument made payable to NE Vocational Rehabilitation. Instruct the consumer that cash should never be mailed. The local office is to proceed with authorizing the full amount of the purchase to the vendor and is not to wait for confirmation that the contribution was received.

Comparable Services and Benefits

VR staff must seek out and utilize all comparable services and benefits to meet, in whole or part, the costs of required and necessary services. Comparable services 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. Clients are required to apply for and use comparable benefits. Considering all available alternatives including those services which can be provided directly by program staff without additional cost to the program, the program will procure the least cost option which meet the recipient's needs.

Rule 72

003.01 Program services and funds may supplement, but not supplant, those services and benefits available to a client and his or her family from anther 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. 

003.02 If any public entity other than the program is obligated under Federal or State law, or assigned responsibility under State policy, to provide or pay for any services that are also considered to be vocational rehabilitation services, then VR funds cannot be used to provide or pay for such services. . .

003.03 Applicants for and recipients of services must apply for and accept any existing comparable service or benefit. Program funds cannot be used to replace comparable services and benefits a recipient is eligible for, but refuses to apply or accept. 

 Exceptions:

  • The benefit must be available to the individual at the time needed to ensure the progress of the individual toward achieving the employment outcome in the individual’s individualized plan for employment. If the benefit is not available when needed use of the benefit is not required;
  • Comparable benefits do not include awards and scholarships based on merit; and
  • An SSA approved Plan for Achieving Self Support (PASS) does not constitute a comparable benefit or service. A PASS is a Social Security work incentive that allows an SSI recipient to set aside income and/or resources for a specified time in order to achieve an employment goal. While funds from a PASS cannot be considered a comparable benefit, PASS resources can complement VR services, particularly to cover additional costs of services, such as home and vehicle modifications, post-secondary training, and self-employment. The development and submittal of a PASS should be encouraged but the choice to do so is the recipient’s decision and is strictly voluntary. The recipient’s decision to not pursue a PASS will have no impact on VR funding for appropriate and necessary goods and services.
Attachment: Purchase_of_goods_and_services_12_.pdf
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