Start Your RSA PD-19-03 Testing Now
July 07, 2020 by Stephanie Kuhnel
Summer has arrived, and the vocational rehabilitation (VR) industry is racing to prepare for major changes in the rules and policies governing the delivery of training and rehabilitation services. Is it too early to start preparing?
The upcoming VR changes are part of the new Rehabilitation Services Administration (RSA) PD-19-03 Policy Directive, which went into effect on July 1, 2020. The directive addresses instructions for the completion of the case service report RSA-911. The report contains a record of demographic and programmatic data for each person served by the VR program. It must meet strict guidelines established by RSA. The first PD-19-03 RSA-911 report is due Nov. 15, 2020.
With more than four months to go until the first PD-19-03 compliant RSA-911 report is due, should agencies be focusing on their VR case data quality and policy compliance now? After all, agency staff are incredibly busy delivering VR services, training for the new PD-19-03 policy directive, and preparing their final RSA-911 report governed by the outgoing PD-16-04 rules, due by Aug. 15, 2020.
Despite the additional work, the best answer is YES.
The cutover from one policy directive to another can be daunting. VR agencies must retrain their staff to correctly enter and update cases in compliance with the new policy rules. Depending upon the scope of the policy change, thousands of errors could suddenly appear in their case management systems due to these rule changes. Any errors of this kind must be identified, analyzed, and corrected. The PD-19-03 is a major RSA policy change and vocational rehabilitation specialists, such as the experts at Encorpe, expect the volume of errors that must be vetted to be significant.
Waiting until Oct. 1, 2020, when RSA opens the RSA-911 submission portal, could be a risky strategy. An agency would have only 45 days to identify and correct any errors, and repair efforts can be complicated. The pressure will be intense as RSA will not accept an RSA-911 report with errors, the submission portal will be closed after 45 days, and there are substantial penalties for “failure to submit.”
Now that the new policy has gone into effect, it is a best practice to begin the transition as soon as possible. Our step-by-step checklist provides a framework for how to get started. In order to fully understand the new policy directive, to correct errors as they pop up, and to have an error-free RSA-911 report to submit before the deadline, agencies should start today.