Comment from Asher, Nancy, Michigan Association for Deaf and Hard of Hearing

Submitted to http://www.regulations.gov Docket number SSA–2009–0040 Revised Procedures and Criteria for Payment of Vocational Rehabilitation Services through the Cost Reimbursement Program Agency: SSA Comments submitted by: Nan Asher Michigan Association for Deaf and Hard of Hearing 5236 Dumond Court, Suite C Lansing, MI 48917-6001 (517) 487-0066, Ext.12 Thank you for issuing this Advance Notice of Proposed Rulemaking (ANPRM). We certainly appreciate this opportunity to express our concerns about the impact to our employment network (EN) from changing vocational rehabilitation (VR) cost reimbursement rules. Responses to to specific questions raised in the ANPRM: 1. Changing VR rules to make the Ticket Program more effective. The current rules penalize our organization for serving former VR clients, we lose Phase 1 Milestones no matter how long ago a VR case was closed or whether or not VR received cost reimbursement. We recommend the following: A) EN would become eligible for Phase 1 milestone payments if the VR case has been closed for 18 months or for a beneficiary with prior VR services who is no longer working when he or she chooses to deposit a ticket with an EN and the EN chooses to accept it. B) Amend the rules to allow Phase 1 milestone payments to an EN when VR does not receive Cost Reimbursement for whatever reason. 2. Changing the list of services for which payment may be made. No comment. 3. Avoiding duplicate services when a beneficiary receives services from an EN prior to VR services. Our organization does NOT refer a consumer to VR unless the consumer needs services we don’t provide, so there is no duplication of services. No circumstances could justify a “clawback” where our organization pays back Phase 1 Milestones or has future milestones reduced if our client decides to seek services from the state VR agency after some payments are made to the EN. This would penalize us for serving anyone who thought they were job-re