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— (03/02/2014) Our agency is attempting to ascertain what RSA considers a legitimate client signature, as there doesn’t appear to be any specific policy guidance. Currently, the VR case management software populates/types the client’s name in the signature field on the IPE and any subsequent amendments. Does this suffice as a legitimate client signature or is a hand written signature required?

From Cecelia Hockett, GVRA:

Currently the Georgia Vocational Rehabilitation Agency VR Program has clients to sign a hard copy document. We will be moving to an electronic case file in the very near future and will be very interested in viewing the responses to this inquiry.


From From Linda Deschenes, RI – Office of Rehabilitation Services:

Good question, RI also would be interested in the responses to this question. The case management system used in RI populates signatures in the same way referenced in your question. As we have not gotten our signature pads operational, RI continues to use the signature page of the “paper” IPE which is then scanned into the electronic case file.


From Terry Sands, MN Vocational Rehabilitation Services:

We have the same question.


From Feona Barnett, Arkansas Division of Services for the Blind:

Arkansas Division of Services for the Blind plans to go-live with the AWARE Software Program April 1, 2014. AWARE will allow us to use electronic signatures on IPE’s and amendments. Eligible individuals and counselors will be able to sign their names on an electronic key pad which will transfer to the signature fields on the IPE Signature Cover Page. Agency policy requires the individual and counselor sign the IPE and amendments.


From David Higginbotham, Louisiana Rehabilitation Services:

LRS requires the consumer’s original signature (i.e. faxed or scanned copy is not acceptable) for the IPE.


From Christopher Deere, Arizona Rehabilitation Services Administration:

The population in the system in and of itself does not suffice. We require either a hard copy (scanned into System 7) signature as evidence or have set up other methods to receive quasi signatures via email. We also are integrating scan pads into our system at which time a signature received in the form via these pads will suffice.


From HarrietAnn Litwin, Delaware Division of Vocational Rehabilitation:

No. We require actual, hand-written signatures on the IPE and on any amendments with substantial services, change of services, etc.


From Kathy Marchione, CT- BRS (general):

We require a written consumer signature on all documents.


From Jennifer Geuther, South Dakota Division of Rehabilitation Services:

In South Dakota a hand written signature is required and we have this requirement written into our counselor manual.


From Andrew Reese, DC Rehabilitation Services Administration – Department on Disability Services:

We require a hand written signature. Our system also populates the signature field with the client’s, counselor’s and any other required person’s names. However, in federal audits, we have had problems when we did not have hand written signatures. Two caveats – we are in the process of moving to an electronic case record, so the signature will be electronic – but we use signature pads and require the client to sign, the same as we do for a printed application.

In our monitoring visit, RSA claimed that our printed referral was so thorough that it qualified as an application – even though the regulations require applications to be signed, and there was no signature line on our referral form.


From David Ritacco, Oregon General:

I don’t believe that a field that could be filled in by a person other than the participant is sufficient. However, if the participant is assigned a password that only they know to enter their signature electronically, I think this is sufficient.

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— (09/04/2013) Nevada is reviewing its policies on dental restoration services. Currently, Nevada provides dental services “only when a dental disability exists which impedes the ability to work or interferes with maintaining an occupation.” We would like to know if other States have specific policies for determining eligibility based on a dental impairment being the sole disability (no other qualifying disabilities exist). Also — what specific guidelines other States may have for providing dental restoration services, including what services are generally excluded.

From Lynn Ritter, Division of Blind Services, Florida:

We do not have a specific policy. We provide dental if the condition causes cosmetic problems severe enough to prevent an individual from obtaining a job which involves serving the public or will cause loss of job unless corrected; results in toxic poisons which cause physical symptoms in other parts of the body or aggravates an already existing disability or is an acute dental condition that interferes with employment and/or the provision of other services.


From Pamela Brauchli, OVR:

PA does not have a sole dental policy. It’s part of our physical restoration policy.


From Michael Shoemaker, Utah State Office of Rehabilitation:

Hello, Jan, Below is Utah’s Vocational Rehabilitation policy regarding dental services from Chapter 14 of our Client Services Manual.

“Dental Restoration: The VR Counselor may determine that dental restoration is appropriate if the condition of the teeth and gums contributes to, or is a result of a physical or mental impairment which, for the individual, constitutes a significant impediment to employment. The VR Counselor determines that the condition is stable and remediable within a reasonable period of time, and the client meets financial need criteria. Dental restoration is appropriate when it will enable the client to achieve the employment outcome listed in the IPE. It is not within the scope of USOR to undertake a program of general dental care. However, it does assume the responsibility for correcting dental difficulties which are impediments to employment, and those closely associated with other impairments that have resulted, or are likely to result in an impediment to employment. Dental services must These services need to be included incorporated in the IPE before they can be authorized. Dental restoration cases requiring extensive crown and bridge work, root canal procedures, expensive capping and other out-of-the-ordinary procedures will be referred to the DRRS Dental Consultant through the District Director or Field Service Director. Unusual cases i.e. TMJ, oral surgery, implants, etc, forward client record through the Field Service Director. Inter-Current Dental Problems: During the rehabilitation process, a client may contact the VR Counselor because of dental problems. Preventative and standard dental work or filling of teeth is not the responsibility of USOR unless such restoration is essential in achieving an employment outcome. In the event that a client has an acute dental problem which prevents the continuation of a rehabilitation program, the VR Counselor may authorize dental care. Exceptions: In the event that an eligible individual’s dental health is of such a nature as to be causing pain, suffering, and other health problems that threaten progress towards an employment outcome, the VR Counselor may justify providing immediate emergency dental care to stabilize the condition and relieve pain.”