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. 

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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.

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1. As services are identified, VR staff  must have a conversation about  the cost of the service and how they will be funded. Nebraska VR 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: 
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Comparable Services:  

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• 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. 
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• VR 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. 
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• 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. 
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• Applicants for and recipients of services must apply for and accept any existing comparable service or benefit. VR funds cannot be used to replace comparable services and benefits a recipient is eligible for, but refuses to apply or accept.\r\n\t
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  • Durable/Medical Goods: Note – If Medicare or Personal Insurance is paying a portion of the cost, VR now is able to consider paying the remainder, so long as the total VR payment portion does not exceed the limits imposed by the Nebraska VR Fee Schedule for the services or goods. Concurrent rules will apply as per our “Assignment Purchases Policy”. In order to successfully carry out such an arrangement the provider must be advised, and willing to adhere to Nebraska VR’s Assignment Purchase Policy. Medicaid Authorization and Payment Procedures
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• 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. 
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• 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).
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• 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. 
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• 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). 
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• Client Accountability. \r\n\t
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​​​​​​​​​​​​​​Client Contribution: 

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• All individuals will be asked and are expected to help pay for the costs of services and keep regular contact with program staff regarding case progression, changes in their personal financial circumstances, and of problems encountered with services or service providers. 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. 
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• Services exempt from client contribution: \r\n\t
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  • service necessary for determining their eligibility for the program
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  • assessment for determination of vocational rehabilitation needs
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  • post-secondary training allowance 
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• If a client chooses to contribute to the cost of their VR service, and the full cost of the service is within VR’s cost containment guidelines there are two options when authorizing:
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VR authorizes the entire amount to the vendor. Once the invoice is received, VR pays it in full and does not wait for client contribution was received. When/if client reimbursement is received, a refund is completed in QE2 against the payment.

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VR authorizes partial amount to the vendor. VR authorizes the full cost of the service minus the amount the client has agree to contribute. VR and the client each pay their amount directly to the vendor.

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If a client elects to pay for the additional cost of a service that is beyond VR’s cost containment guidelines, only option #2 can be used. VR cannot authorize more than is allowable per cost containment guidelines and then be reimbursed (e.g. client chooses hearing aids that exceed Medicaid rates, and agrees to pay the additional cost. VR can only authorize at Medicaid rates; client is responsible for the balance of the payment).

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Under no circumstances are VR staff to accept from the client any cash, check or other financial instrument. The local office should provide the client with a stamped envelope, pre-addressed to the State Office. The client is responsible for preparing and mailing his/her check, money order, or any other financial instrument made payable to Nebraska VR.

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• 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 Client Accountability. Document in the task note the purchase justification and rationale for the agreed upon choice of services, goods or supports. Include how informed choice was provided, cost estimates, least cost option, client contribution, comparable benefits and services. Refer to attached Purchase of Goods and Services guidelines for further information. 
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• 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. Rule 72 Exception
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 Exceptions for client contribution and comparable service and benefits search:

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• 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;
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• Assessment for determining eligibility and vocational rehabilitation needs
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• Auxiliary aids and services (interpreter, closed captioning, etc.) to provide access to VR services. VR will not assume the responsibility of other programs or service providers, such as postsecondary training institutions, community rehabilitation programs, medical facilities, and placement agencies, for providing auxiliary aids and services for effective communication.
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• Awards and scholarships based on merit; and
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• 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.
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Client Contribution  

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

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Under no circumstances are VR staff to accept from the client any cash, check or other financial instrument. 

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

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• Auxiliary aids and services (interpreter, closed captioning, etc.) to provide access to VR services. 
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• Assessment services for determination of eligibility and vocational rehabilitation needs
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• Post-secondary training allowance described in the chapter on post-secondary training.
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Comparable Services and Benefits

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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.

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Rule 72

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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. 

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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. 

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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. 

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 Exceptions:

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• 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;
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• Comparable benefits do not include awards and scholarships based on merit; and
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• 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.
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Service & Device Application - English