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Public Comment

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The Workforce Innovation and Opportunity Act (WIOA) requires the governor of each state to submit a four-year unified or combined state plan outlining the state’s workforce development strategy. The plan can be viewed on the Department of Labor and Industry’s website, and the draft for the 2024–2028 plan is available here.

Pennsylvania’s Combined State Plan includes the six WIOA Core programs: Adult, Dislocated Worker, Youth, Wagner-Peyser, Adult Basic Education, and Vocational Rehabilitation. It also includes the following optional programs:

  • Career and Technical Education Programs-Perkins Act
  • Temporary Assistance for Needy Families Program
  • Trade Adjustment Assistance for Workers Programs
  • Jobs for Veterans State Grants Program
  • Senior Community Service Employment Program
  • Reintegration of Ex-Offenders Program
  • Community Services Block Grant
  • Unemployment Insurance

Some specific areas of interest to our members include the following goals:

  • Empowering individuals paid subminimum wages through 14(c) waivers to obtain CIE;
  • Expediting the Integrated Vocational Engagement & Support Team (InVEST) Project to assist individuals with disabilities, families, and community businesses with CIE engagement, supports, and services/resource coordination;
  • Increasing competitive integrated employment (CIE) opportunities for individuals with disabilities;
  • Increasing transition services for students with disabilities; and
  • Increasing statewide collaboration with the Bureau of Special Education (BSE) and the Office of Developmental Programs (ODP) to expand Pre-ETS across Departments.

Public comments will be accepted on Pennsylvania’s WIOA Combined State Plan until 5:00 pm on Tuesday, January 16, 2024. Please submit your comments electronically. Written comments may also be submitted by mail to:

PA Workforce Development Board
651 Boas Street | Room 514
Harrisburg, PA 17121

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The Pennsylvania Department of Human Services (DHS) is developing an 1115 Medicaid program, Bridges to Success: Keystones of Health for Pennsylvania (Keystones of Health). DHS hopes to use this program to make health care more accessible, improve quality of care and services, and design and evaluate innovative strategies in health care to help people live healthier lives. The department’s goal and vision for the waiver is to address Pennsylvania’s Medicaid participants’ health-related social needs with interventions that are both lifesaving and cost saving. Visit the Keystones of Health web page for more details.

Keystones of Health will focus on four key areas:

  • Reentry from correctional facilities;
  • Housing supports;
  • Food and nutrition supports; and
  • Multi-year continuous eligibility for children up to age 6.

DHS is offering the public the opportunity to come to virtual forums to learn more about Keystones of Health and the proposed services. During the forums, the public will be able to ask questions and submit comments. If you are interested in joining the public forums, the information is below:

Public Forum 1

  • Date: Monday, December 11, 2023
  • Time: 12:00 pm – 1:00 pm
  • Register for Session 1
  • Join by phone: 312-626-6799; Webinar ID: 982 3951 9594

Public Forum 2

  • Date: Tuesday, December 12, 2023
  • Time: 6:00 pm – 7:00 pm
  • Register for Session 2
  • Join by phone: 312-626-6799; Webinar ID: 980 3834 3590

Public Forum 3

  • Date: Friday, December 14, 2023
  • Time: 9:00 am – 10:00 am
  • Register for Session 3
  • Join by phone: 312-626-6799; Webinar ID: 951 7040 4572

Please register to participate virtually. When you register, there will be an option to add the Public Forum to your calendar. Registration is not necessary to join by phone. Closed captioning will be provided during each public forum.

DHS also invites you to submit written comments on the draft application from December 2, 2023, through January 2, 2024, through the Public Comment Form.

View the Press Release

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Image by Werner Moser from Pixabay

On November 7, 2023, RCPA submitted comments to the Department of Labor’s Hour and Wage Division regarding the proposed rule “Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales, and Computer Employees (RIN 1235-AA39).” While we understand the need to modernize and update the Fair Labor Standards Act exemption regulations, RCPA strongly urges DOL to re-examine the proposed new salary threshold in a manner that considers the unique pressures on health care providers, as well as regional variations in the cost of living and average salary for human services providers. As currently written, the proposal unfortunately does not consider the implications of current health care funding for safety net services. Thus, the current proposal would have a potentially devastating effect on health care organizations serving low-income individuals with serious and complex disorders and disabilities, resulting in the need for service cutbacks and program closures.

You can read the full comments here.

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The Department of Human Services (DHS) has made the Medical Assistance (MA) and Children’s Health Insurance Program (CHIP) Managed Care Quality Strategy (MCQS) for the Commonwealth available for public review and comment. The MCQS is an updated version of the previous strategy submitted to the Centers for Medicare and Medicaid Services (CMS) in December 2020 and accounts for the ongoing post-pandemic delivery system pressures that have affected how managed care organizations (MCOs) deliver care. The MCQS may be viewed online. Comments may be submitted via email, and those received within 30 days will be reviewed and considered. Additional information is available on the Pennsylvania Bulletin.

If you have any questions, please contact Fady Sahhar.

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Image by Werner Moser from Pixabay

The Administration for Community Living (ACL) is seeking input on a proposed rule to establish the first-ever federal regulations for adult protective services (APS) programs. Instructions for submitting comments and registering for an informational webinar can be found on ACL’s website and below.

APS programs across the country support older adults and adults with disabilities who experience, or who are at risk of, abuse, neglect, self-neglect, or financial exploitation. APS programs investigate reports of maltreatment; conduct case planning, monitoring, and evaluation, and provide, or connect people who have experienced maltreatment to, a variety of medical, social service, economic, legal, housing, law enforcement, and other protective, emergency, or support services to help them recover. Over the past decade, ACL has led federal efforts to support the critical work of APS programs through a variety of initiatives.

First-Ever Federal Regulations for APS

The proposed rule aims to improve consistency and quality of APS services across states and support the national network that delivers APS services, with the ultimate goal of better meeting the needs of adults who experience or are at risk of maltreatment. To those ends, the proposed rule:

  • Establishes a set of national standards for the operation of APS programs that all state APS systems must meet. These standards formalize — and build upon — the existing National Voluntary Consensus Guidelines for State APS Systems.
  • Establishes common definitions for the national APS system to improve information sharing, data collection, and standardization between and within states.
  • Requires state APS systems to develop policies and procedures, consistent with state law, for coordination and sharing of information to facilitate investigations with other entities, such as state law enforcement agencies and state Medicaid agencies.
  • Requires state policies and procedures to be person-directed and based on concepts of least restrictive alternatives.
  • Establishes requirements for data collection, retention, and reporting.
  • Establishes requirements for mandatory staff training and ongoing education on core competencies for APS staff and supervisors.

ACL has created a fact sheet with highlights of key provisions of the rule, and the full text of the proposed rule can be found on the Federal Register website.

Input Needed

The proposed rule is the culmination of many years of engagement with stakeholders from APS and long-term care ombudsman programs, as well as disability advocates, from across the country. It also reflects input received through several listening sessions, extensive research, and analysis of data from a 2021 survey of 51 APS systems, ACL’s National Adult Maltreatment Reporting System, and policy profiles from APS programs in all states and territories.

ACL now seeks feedback on the proposed rule from all who are interested in improving implementation of APS programs and services. Input from the aging and disability networks and the people served by APS programs is particularly crucial.

Comments will be accepted for 60 days, beginning when the proposed rule is officially published in the Federal Register (which currently is scheduled for Tuesday, September 12). Instructions for commenting, along with the comment deadline, can be found in the Federal Register notice and on ACL’s website.

An informational webinar will be held on Monday, September 18, at 11:30 am ET. Advance registration is required.

For additional questions, contact Fady Sahhar.

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Last week, the US Department of Health and Human Services (HHS) Secretary Xavier Becerra hosted a press conference to announce a rule proposed by the HHS Office for Civil Rights that would update Section 504 of the Rehabilitation Act of 1973. This is the first time these critical regulations will have been updated since they were originally signed in 1977, after four years of tireless advocacy and a 28-day protest led by disability civil rights leaders.

Updates to the rule include:

  • Clarifications on the obligations to provide services in the most integrated setting appropriate to a person’s needs, consistent with the Supreme Court’s decision in Olmstead v. L.C;
  • Medical treatment decisions are not based on biases or stereotypes about people with disabilities, judgments that an individual will be a burden on others, or beliefs that the life of an individual with a disability has less value than the life of a person without a disability;
  • Adoption of standards for accessible diagnostic medical treatment;
  • Adoption of the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA, which are accessibility standards for websites and mobile applications;
  • Clarification of requirements in HHS-funded child welfare programs and activities to help eliminate discriminatory barriers faced by children, parents, caregivers, foster parents, and prospective parents with disabilities; and
  • Prohibition of the use of value-of-life assessments in treatment decisions.

Read the official announcement, full rule, fact sheet, and instructions on how to provide comments on the HHS website. If you have any questions, please contact Fady Sahhar.

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