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CMS Issues 1915c Informational Bulletin

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CMS Issues 1915c Informational Bulletin

September 19, 2011

The bulletin (a "step-below" a state Medicaid directors letter) was released Friday and represents a two-year effort to provide "clarification of existing CMS guidance on development and implementation of §1915 (c) Waivers regarding employment and employment related services."

ANCOR will work with other national groups, as well as internally, to analyze the bulletin and affects—especially on day habilitation and pre-vocational services.

Note the following highlights of the bulletin:

  • Modifies both the prevocational services and supported employment definitions to clarify that volunteer work and other activities that are not paid, integrated community employment are appropriately described in pre-vocational, not supported employment services;
  • Explains that pre-vocational services are not an end point, but a time limited (although no specific limit is given) service for the purpose of helping someone obtain competitive employment;
  • Adds a new core service definition by splitting what had previously been supported employment into two definitions: individual and small group supported employment; and
  • Includes a new service definition for career planning that may be separate or rolled into the other employment related service definitions.