VRS E1 PBA and General PBA Frequently Asked Questions
VRS/SSB Staff and VRS/SSB Community Partners are invited to submit additional questions via this link: Questions about VRS PBAs.
PBA Resources
What resources are available with the specifics of the PBA and E1 process?
Resources are being added to the DEED-VRS Community Partners Guide website. Additional webinars will cover specifics of the General and E1PBA processes (late July or August).
Where can the 6/29/21 PBA Training recording and presentation be found?
The training recording and presentation are being added to the DEED-VRS website in the Community Partners Guide.
Where can I find forms for the E1 PBA and General PBA?
Forms are available on the DEED-VRS website in the Community Partners Guide.
PBA Billing/Process
Does VRS need the first monthly progress report from Community Partners before paying Milestone 1?
No, only the signed Placement Plan provided by the partner is necessary to pay a Milestone 1 invoice.
Is it still required to have the first 60-day meeting scheduled before the payment of the first milestone? (for both general and E1?)
Yes, the 60-day meeting should be scheduled before the Placement Plan meeting concludes with the Core Members (Job Seeker, Placement Professional and VR Counselor) agreeing to a date and time.
Will VRS make a payment for a milestone if the provider has not submitted all Monthly Progress Reports to date for that individual?
No, VRS will not make a payment for a milestone unless all Monthly Progress Reports are received and satisfactory from the previous milestone paid to the current milestone being invoiced.
Regarding payment for Milestone 3: do Community Partners need to resubmit all progress reports occurring since the Milestone 2 payment or just ensure that the reports have been sent to the VR counselor at the appropriate times throughout that period?
The Placement Professional should submit the last Monthly Progress Report with the Job Closure information with an invoice for Milestone 3. The VRS staff will ensure ALL Monthly Progress Reports since the last Milestone payment have been received before approving Milestone 3 payment.
Would the first Monthly Progress Report be required a month after the placement plan meeting?
The first monthly progress report is required 10 days after the end of the calendar month. If a placement plan meeting happens toward the end of a month, there can be discretion utilized to allow the partner to just complete the next month of reporting. Communication outside of the progress report is strongly encouraged and is best practice.
How could placement give VRS employment verification within 7 days when it should be on the monthly report and that will be due by the 10th of the following month?
The partner will use the Monthly Progress Report and complete the job details. This should be sent within seven days of the first shift worked (regardless of time of month). Partners should continue to submit a regular monthly progress update on the 10th of the following month. It is possible two reports are sent in one month based on timing of a hire.
How should VRS staff document employment in WF1 if they can't yet start the 90-day job stability clock?
VR staff should enter employment details into WF1. If job coaching is layered, VR staff can move the case into "Job Coaching" status in WF1. Once employment stability is reached the status should be changed to "In Employment" to track Achieved 90 Days of Employment Stability.
What contact means are acceptable for a 60-day meeting, if a participant is unable to meet in person or does not have access to technology to do a virtual meeting?
We want to ensure the 60-Day Meeting is a planned meeting and not a quick phone call or email check-in. This meeting is an important part of Job Placement services. VR recommends a "live" in-person or virtual meeting, but we want to respect the Job Seeker's needs. If there is no option to meet either virtually or in person, this meeting can be by phone if it is a scheduled and structured meeting with all core members present (Job Seeker, VRS Counselor and Placement Professional).
Is there an option to pay a milestone for an individual attaining an intermediate job while still in placement for the specific employment goal?
PBA is used for a specific employment goal on the employment plan as determined by the VR counselor and the participant. An "Intermediate Job" is a term used for Pre-ETS services and refers to employment that is experiential in nature. Payment for Milestone 2 cannot be made for an "Intermediate Job."
VRS Placement Professional enters their information directly into WF1 - Is a copy of the Monthly Progress Report scanned into WF1 under "Document Summary" acceptable as having been entered into WF1?
Yes, it is acceptable to upload the Monthly Progress Report directly into EDS to count for internal VR placement documentation.
Do Community Partners need to use VRS's template Placement Plan form, or can Community Partners incorporate required elements into their internal electronic Placement Plan form?
The Placement Professional can use their own version of a Placement Plan for General PBAs and E1 PBAs as long as it incorporates all the key elements in the VRS template.
When did the "12 Months in a PBA" clock start for current participants?
The "12 months in a PBA" clock starts the day the Placement Plan is signed, including current participants. For example, if a current participant's PBA started 8/1/2020, then the PBA will hit 12 months on 8/1/2021.
When should Community Partners start using a Monthly Progress Report instead of the bi-monthly Communication Updates?
Communication requirements from Community Partners during a PBA have moved from bi-monthly communication updates to a Monthly Progress Report for both the General PBA and the E1 PBA.
- June 30: is the last submission of bi-weekly Communication Updates. VRS asks partners to ensure they are caught up on communication updates as of June 30.
- Starting July 1: partners will start using the Monthly Progress Report template. The first report will be for PBA activities in July, and monthly reports are due no more than 10 days after the end of the month. Thus, the first report (for July activities) will be due by August 10.
What will authorizations for a General PBA and an E1 PBA look like?
Community Partners can expect to see new service titles to distinguish between the E1 PBA milestones and General PBA milestones on authorizations July 1 moving forward. VRS staff will not be changing authorizations for PBAs that were authorized prior to July 1 to the new service types and titles – the new service titles will be used simply moving forward.
General PBA Service Type and Titles
- Service Type: Job Placement Services - General PBA
- Service Titles:
- 1: Signed Placement Plan Meeting ($1,330)
- 2: Employment First Shift Completed ($1,200)
- 3: Successful Placement Closure ($1,270)
- *OCSS Differential ($400)
E1 PBA Service Type and Titles
- Service Type: Job Placement Services - E1 PBA
- Service Titles:
- 1: Signed Placement Plan Meeting ($1,330)
- E1: 120-Days of Service ($1,200)
- 2: Employment First Shift Completed ($1,200)
- 3: Successful Placement Closure ($1,270)
- *OCSS Differential ($400)
E1 PBA
Will Community Partners have the ability to complete the Placement Plan in WF1 once it is available in September?
No, providers won't have WF1 access, but will be asked to send the signed Placement Plan as is current practice.
Will Why does VRS need to have an extended 90-day clock for employment stability with individuals on waivers when the county has taken over funding long-term supports?
RSA requires that VRS support and follow an individual until they have Achieved 90 days of Employment Stability regardless of waiver.
What happens to the Employment Stability clock if there are some intermittent job coaching hours required? If an individual can never go without job coaching, then what is the definition of "stability"?
For VRS, Employment Stability is defined in Chapter 6. You can also reference the trainings in ELM.
Why are there two 90-Day clocks? And how are the different?
"Employed for 90 days" is for PBA Milestone 3 payment to the Community Partner. "Achieved 90-days of Employment Stability" is an RSA metric. VRS uses the 90 days of Employment Stability to measure employment stability for purposes of considering VRS case closure. This is true for both General and E1 PBAs and is the same as our current policies.
When is the E1 milestone paid?
The E1 milestone is paid when the partner invoices for 120 days of placement services (Date of Service on invoice is 120 days from date of placement plan meeting). The corresponding Monthly Progress Report should be submitted with the invoice and VR staff should ensure that all Monthly Progress Reports have been received since the last milestone was paid.
For the new E1 milestone, if a person is employed before the 120 days of service, would a Community Partner be allowed to bill that new milestone?
The E1 milestone is paid at day 120 in service. This clock starts the day the Placement Plan is started. Whether a Job Seeker is in job search or follow up, if they are still being served under the E1 PBA at day 120, the milestone can be billed for.
If a participant has one of the four waivers, but won't need job coaching or long-term follow up services, does VRS have to use the new E1 PBA or is a traditional PBA acceptable if otherwise appropriate? And should VRS still involve the case manager in the initial placement meeting?
When a Job Seeker has one of the four Medicaid waivers, this starts an E1 PBA. It is best practice to connect with the waiver case manager to discuss benefits and potentially available funding supports available to the Job Seeker.
Can a VRS employment plan amendment be completed/signed now and then authorized for E1 PBA starting in July? Or does the plan need to be updated/done after July 1 to allow for the new service title to be used?
VRS can update Employment Plans at any time. Authorizations for E1 PBA cannot take place until after July 1.
If an individual currently in a General PBA and has one of the four waivers should VRS switch to an E1PBA after July 1?
If the individual is in a job search/PBA, it would be business as usual. An E1 PBA would be available to anyone with a Medicaid waiver who has not started job search prior to 7/1/21. Additionally, if a current Job Seeker on a waiver reaches 12 months of job development services on or after July 1, 2021 in a PBA and there is agreement to continue job development services, the existing PBA can be cancelled and an E1PBA can be authorized.
Individuals with waivers who have support through the waiver, and either lose their job or decide they want to search for a new job, do they go back to VRS for the E1PBA?
If an individual was in an E1 PBA and they lost their job, the open E1 PBA would continue to fund the search for another job.
If an individual is on a waiver and has development services authorized (through the waiver), and they are now ready to find a job, should a referral to VRS be made? Or can the individual choose to find work through their waiver?
When a Job Seeker wants to begin their job search for competitive, integrated employment, a referral to VRS/SSB should be made. VRS/SSB is the funder for Job Placement Services as part of the "Find" phase.
Will the Occupational Communication Specialist Services (OCSS) Differential for PBA be the same with E1 PBA?
Yes.
How would E1 PBA relate to people who are referred for Individual Placement and Support (IPS)?
When an individual has one of the four Medicaid waivers and is referred to an IPS project for job search, an E1 PBA would be authorized, and the waivered case manager would be invited to the team. The IPS approach and principles would continue as usual.
When can Milestone 3 be paid with made with Connect 700?
Milestone 3 can be invoiced and paid 90 days after the first day of the official probationary period starts.
If an individual successfully closes on a E1 PBA and then loses the job, does the individual come back to VRS to start a new PBA or can the individual go through the waiver?
VRS/SSB is the primary funder for the "Find" phase. If someone loses their job, a referral to VRS/SSB for job search assistance would be the appropriate step. VRS/SSB can open a new case for the person and provide job search supports.
PBA Follow-Up Services
What is the process for transitioning the funding for long-term supports to the county/waiver?
This information will be available on the E1MN website on July 6, 2021.
Are we not supposed to refer for placement until we know long-term supports are in place? How does that work with this process?
Correct, for VRS, this practice remains the same. If an individual requires long-term support for success, this should be confirmed prior to putting Placement and Follow-Up Services on an Employment Plan. This will be addressed in more detail in an upcoming training.
Would onboarding and orientation help be part of follow-up or job coaching? Does onboarding/HR paperwork count as the first day of employment?
First-day paperwork and orientation are generally considered "Follow-Up Services." Depending on the disability and individual learning needs there could be a case for job coaching.
If a Job Seeker requires all the activities listed under follow-up services as well as job coaching services, does VRS distinguish between each and, if so, how would the Community Partner go about this?
If a person requires job coaching, the Community Partner would then be providing two services. Follow-Up Services with its required paperwork and process and Job Coaching with its required paperwork and process.
At what point should a Community Partner discuss potential job coaching needs with VRS staff, particularly when the Community Partner is already providing "follow-up services" to the job seeker in their new position?
The conversation about potential job coaching needs should occur at the Placement Plan Meeting and 60-day check ins. The request for a job coaching authorization should occur when the offer is made, prior to job start date. If a Job Seeker starts working with follow-up support and the core team agrees job coaching is needed, then the request should be made at the time for a job coaching authorization.
PBA and Job Coaching Services
Why was job coaching unbundled from the PBA?
The federal funder and regulator for the Vocational Rehabilitation program, the Rehabilitation Services Administration (RSA), directed Minnesota to unbundle job coaching from the Job Placement and Follow-Up Services Performance Based Agreement. RSA wants to ensure the need for services such as job coaching are determined on an individualized basis.
Do the job coaching hours need to be approved by a supervisor?
If job coaching hours will exceed 60 hours total, VRS staff will need RAM approval before authorizing more hours. More than 60 hours of job coaching can be authorized but this will be a case-by-case decision.
Should VRS authorize for 60 hours of job coaching all at once?
No, the amount of job coaching hours authorized will be determined on an individual basis with agreement between the Community Partner and VRS.
Do Community Partners need to amend their contracts to add job coaching separate from the PBA?
If a Community Partner does not have Employment Supports/Job Coaching for Short-Term Job Supports on their PT contract, they should contact the Community Partnerships team to have their PT contract amended.
Is a separate authorization required when the need arises for job coaching?
Yes, a separate authorization must be generated for job coaching if this is layered with a PBA.
If job coaching is separate from the PBA, do Community Partners need to complete separate paperwork for the services?
Yes, if a person requires job coaching, the Community Partner would then be providing two services. Follow Up Services with its required paperwork and process and Job Coaching with its required paperwork and process.
Should Community Partners contact VRS to about potential job coaching needs, or will the VRS Counselor contact Community Partners?
It is best practice for the Community Partner to contact VRS about potential job coaching needs. As always, early and frequent communication regarding potential job coaching needs is expected and best practice.
If/When job coaching is paid for by the waiver, is the VRS job coaching report still required?
A VRS coaching report is only required for invoicing for VRS funded coaching.
Which organization, VRS or waiver, is responsible for funding job coaching services during the "Employed for 90 days" phase? Can the waiver pay for job coaching instead of VRS, during the E1 PBA and prior to case closure?
VRS will fund job coaching (if needed) until the person has reached employment stability. Once a VRS/SSB counselor has determined employment stability, long-term supports will be funded by the waiver employment support service as part of the "Keep" phase.
How does travel relate to PBA?
"Travel Expense to Provider" and "Transportation to Community Partner" are still bundled into a PBA and cannot be authorized separately for a PBA. However, if job coaching is layered with a PBA, VRS staff may layer "Travel Expense to Provider" and "Transportation to Community Partner" for the layered job coaching. Agreement on either or both services must be made prior to the start of services. One authorization with multiple lines (job coaching "x" hours, travel "x" hours) will be created as agreed upon.
Will a VRS authorize for an intake with Job Coaching layered with a PBA?
If the same Community Partner that provides a PBA will also continue with the individual for hourly Job Coaching services, VRS will not authorize for a separate intake for Job Coaching. The Community Partner will already be well acquainted with the individual and thus no intake is necessary. If a different Community Partner provides the hourly Job Coaching than the Community Partner who provided a PBA, VRS staff can consider authorizing for an intake for Job Coaching services. This will be true for all services "layered" with the PBA. More to come on layered services in the 6/29 training.
What are Purchasing Violations and how do they relate to Job Coaching?
State law requires prior approval and prior "encumbrance" for any expenditure of funds. That prior approval and encumbrance comes in the form of an authorization from VRS. If VRS pays for services performed before an authorization issued or pays for services above the allotted hours on the authorization, VRS incurs a purchasing violation. A purchasing violation is sometimes referred to as an "MS16" which references the state law that requires this prior approval and prior encumbrance before a service takes place.
It is best for VRS staff and Community Partner staff to be in close communication throughout the PBA to discuss potential Job Coaching needs. This will ensure that necessary authorizations for individuals are completed in a timely fashion and there are no issues with purchasing violations.
- VRS will not incur purchasing violations for hourly Job Coaching services.
- ONLY Job Coaching hours that have been authorized prior to the Job Coaching services occurring and ONLY Job Coaching hours that fall within the number of prior authorized hours will be paid by VRS.
- Prior to authorizing, the number of authorized hours for Job Coaching services must be negotiated with VRS staff and Community Partner staff.
- Requesting hours for Job Coaching services is the responsibility of Community Partner staff and is granted at the discretion of VRS staff.
- Job Coaching services that occur BEFORE an authorization is active will result in no payment for that time by VRS.
- Job Coaching hours in EXCESS of the number of authorized hours will result in no payment for that time by VRS.
E1MN
What activities are included with engage and plan phases? We have many people referred by the county to our program to have a Benefits Analysis (BA) completed, should we send them back to the county for a BA?
This information will be available on the E1MN website on July 6, 2021.
If a person has a waiver and they lose their job, do they have to be re-referred to VRS to go through the find phase again or can they work with their community provider to find another job without going through VRS again?
If the participant loses their job while still in an active PBA, the PBA will continue, and the VR file stays open. After the VR file is closed, the participant should be re-referred to VR to do the Find phase of waivered employment services again.
Do you know when DHS is training county case workers about the E1 PBA framework/ MOU?
Waiver case managers are trained by DHS. Look up training timelines for DHS.
How can/where do I register or find additional trainings?
Trainings & Coffee chats registration: Disability Hub MN - E1MN trainings and events.
Can VRS add a question about waivers to the VRS application?
More detailed questions about waivers have been added to the VRS Applicant Information form that is collected at the time of application.
Is VRS willing to make the VR application available directly to the case manager AND/OR the CRP to help the participant to complete the application?
No. VRS is responsible for providing these forms to a potential participant.
As a provider, we are at capacity for waivered Development, at what point do we start encouraging individuals/CM to contact VRS for an intake? Because availability of staff will be after July 1.
Participants can apply at any time, even those using waivered funding for employment services.
There are parts of the state that do not have VRS Community Partners with the capacity to provide long-term supports available. What do we do in this situation?
There is no change from previous VRS guidance. If the waiver case manager does not agree to fund long-term supports or if long-term supports are not available, then VRS would not proceed with services if the person needs long-term employment supports.
How will VRS staff know if someone has a waiver? Does VRS staff need to verify? What about adults who self-refer as sometimes they aren't sure if they are on a waiver or have a case manager.
VRS staff can look at DB101 and do a "Benefits Look-Up" to verify a waiver. For an E1 PBA, the waiver case manager is a part of the placement team and vocational planning process. Keeping them updated is critical. It is likely the waiver case manager is part of the referral to VRS.
What are the waivers and the definition of services?
The Guide to Waivers page is published on the Hub site in the Work toolkit. It has a "What are waivers?" section and the "FAQ's from VRS/SSB and schools" which includes a lot of helpful tips.
These are the four Medicaid waivers that initiate the E1 PBA:
- Brain Injury (BI) Waiver for people with acquired or traumatic brain injuries who need the level of care provided in a nursing facility that provides specialized (cognitive and behavioral supports) services for people with brain injury or neurobehavioral hospital level of care.
- Community Alternative Care (CAC) Waiver for chronically ill and medically fragile people who need the level of care provided in a hospital.
- Community Access for Disability Inclusion (CADI) Waiver for people with disabilities who require the level of care provided in a nursing facility.
- Developmental Disabilities (DD) Waiver for people with developmental disability or related condition who need the level of care provided in an Intermediate Care Facility for Persons with Developmental Disabilities (ICF/DD).
What about VRS Community Partners that are not interested in 245D licensure?
VRS will not require VRS Community Partners to obtain a 245D license. Each Community Partner will make that decision for themselves. In many cases, a VR participant will already be connected with a community partner who worked with them in the "Engage" and "Plan" part of the E1MN process. That participant might choose to continue with the same community partner to assist them with the "Find" phase, and then continue working with the community partner when they move back to DHS funding during the "Keep" phase. In this case, there is a benefit to being a 245D licensed provider and dually enrolled with DHS and VRS so a participant can have a seamless continuum of services. However, community partners who do not have a 245D license can provide E1 PBA services and may be selected over a dually enrolled community partner if the VR participant and VR counselor feel this is the best match.
