Corvid Updates
LRS Bulletin #7
May 15, 2020
MEMORANDUM
TO: LRS Community Rehabilitation Programs
FROM: Melissa Bayham
LRS Director
RE: Service Delivery During COVID-19 Pandemic (Phase 1)
Please see the below updated guidance related to service delivery during the COVID-19 pandemic. Please ensure that you are adhering to the requirements set forth in the Governor’s Proclamation Number 58 JBE 2020 and Proclamation Number 59 JBE 2020.
The use of teleconferencing and other virtual practices may still be used to provide certain services when necessary.
Employment Services:
Community-Based Assessments must be provided in person and cannot be provided virtually. Observations are a significant part of the assessment process. These assessments can be conducted if you are able to adhere to the required guidelines set forth in the Governor’s Phase 1 Proclamations.
Vocational Assessments must be provided in person and cannot be provided virtually. Vocational Assessments can be conducted if you are able to adhere to the required guidelines set forth in the Governor’s Phase 1 Proclamations.
Job Readiness Training may be provided virtually. The Progress Report must include the delivery method of services. The Progress Report should indicate the competencies that were addressed during the training session and the consumer’s progress.
Job Development may be provided virtually. This service must be specific to the consumer, and the Progress Report must indicate consumer involvement.
Job Coaching Services may be provided virtually. According to guidance received from the Rehabilitation Services Administration, “With regard to ‘ongoing support services’ both the statute and regulations permit the VR agency to provide these services to individuals with the most significant disabilities either at the worksite or, in specific circumstances, especially at the request of the individual, away from the worksite. Therefore, VR agencies and their service providers may deliver these services remotely or virtually as well. Ongoing support services are defined at Section 7(27) of the Rehabilitation Act and 34 CFR 361.5 (c)(37), which include services such as job coaching, follow-along, and other services needed to support and maintain an individual with a most significant disability, including a youth with a most significant disability, in supported employment. Ongoing support services also include the assessment of employment stability and provision of specific intensive services or the coordination of such services at least twice a month (Section 7(27)(B) of the Rehabilitation Act and 34 CFR 361.5 (c)(37)(iv)).” The provider must communicate with the counselor regarding the support plan.
Pre-ETS may be provided virtually, with the exception of all Work-Based Learning Experience (WBLE) activities. These are exploratory, community-based experiences. New WBLE services can be provided if you are able to deliver these services within the Governor’s Phase 1 guidelines.
Additional information:
LRS will not recommend or approve meetings through social media platforms such as Facebook, Twitter, and/or Instagram as there are significant issues around security, confidentiality and HIPAA compliance.
Each web-based service has advantages and limitations, and your agency should determine what works best for your situation. In selecting a virtual format, we strongly recommend that you consider:
- Security vulnerability-is the platform encrypted
- Confidentiality- will confidentiality be maintained during the meeting
- Accessibility- will that platform be accessible for all abilities
- Reliability- confidence in the ability to provide the service when agreed upon
- Connectivity quality- will your agency be able to handle the connections
- User friendliness- will use be easy or understood by all involved
- Affordability-is it free or not a financial burden to your agency, as LRS will not reimburse for charges for virtual platforms
The quality and content of services should be consistent with services provided in-person, with the only difference being that the service is being provided through a virtual platform. Services cannot be conducted using pre-recorded lessons, unless approved by the Director. Putting a lesson on a virtual platform does not by itself constitute a service if no action is taking place other than the participant watching a video. There must be wrap around activities conducted by the vendor in addition to the pre-recorded lessons.
Please contact your Regional Manager regarding any questions as to whether your alternative methods of service delivery are allowable. Counselors will contact consumers upon the receipt of invoices and progress reports to verify that the services were provided prior to payment.
If an LRS consumer does not wish to meet virtually or work during the pandemic, please notify the consumer’s rehabilitation counselor. Many consumers have health conditions that need to be taken into consideration when planning for meetings and continued services. Consumers that wish to pause services will be placed into services interrupted until they are ready to resume services.
Further guidance may be provided as new information is learned. Please contact your Regional Manager with any questions or concerns.