Request for Information on Potential Stay-at-Work/Return-to-Work Demonstration Projects, 45618-45623 [2017-20338]
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[FR Doc. 2017–20916 Filed 9–28–17; 8:45 am]
BILLING CODE 4510–29–P
DEPARTMENT OF LABOR
[Agency Docket Number: DOL–2017–0003]
Request for Information on Potential
Stay-at-Work/Return-to-Work
Demonstration Projects
Office of Disability
Employment Policy, DOL.
ACTION: Request for information.
AGENCY:
Washington State’s workers’
compensation system runs several
promising early intervention programs
including the Centers of Occupational
Health and Education (COHE) and the
Early Return to Work and the Stay at
Work programs, which provide early
intervention and return-to-work services
for individuals with work-related health
conditions and their employers. The
President’s FY2018 budget proposed
that the Office of Disability Employment
Policy (ODEP) at the U.S. Department of
Labor (DOL) and the Social Security
Administration (SSA) jointly conduct a
demonstration testing the effects of
implementing key features of these
programs in other states and/or for a
broader population beyond workers’
SUMMARY:
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compensation. To do that, we anticipate
funding two to three states to operate
projects with key elements drawn from
the Washington State programs
mentioned above, with an increased
emphasis on access to employmentrelated supports, or fund the expansion
of existing programs to include
increased access to employment-related
supports. The ultimate policy goal is to
increase employment and labor force
participation of individuals who have or
are developing work disabilities. This
request for information (RFI) seeks
public input on how the proposed
demonstration projects can best be
designed to promote labor force
attachment, coordinate employment and
health services, and support injured and
ill workers in returning to and
remaining at work. The input we receive
will inform our deliberations about the
possible design of a future
demonstration project.
DATES: Comments must be received by
October 30, 2017.
ADDRESSES: You may submit comments
by any one of three methods—Internet,
fax, or mail. Do not submit the same
comments multiple times or by more
than one method. Regardless of which
method you choose, please refer to
Docket No. DOL–2017–0003in your
comment pages so that we may associate
your comments with the correct docket.
Caution: In your comments, you
should be careful to include only the
information that you wish to make
publicly available. We strongly urge you
not to include in your comments any
personal information, such as Social
Security numbers or medical
information.
1. Internet: We strongly recommend
that you submit your comments via the
Internet. Please visit the Federal
eRulemaking portal at https://
www.regulations.gov. Use the ‘‘Search’’
function to find docket number DOL–
2017–0003. The system will issue a
tracking number to confirm your
submission. You will not be able to
view your comment immediately
because we must post each comment
manually. It may take up to a week for
your comment to be viewable.
2. Fax: Fax comments to (202) 693–
7888.
3. Mail: Mail your comments to the
Office of Disability Employment Policy,
U.S. Department of Labor, 200
Constitution Avenue NW., S–1303,
Washington, DC 20210.
Comments are available for public
viewing on the Federal eRulemaking
portal at https://www.regulations.gov or
in person, during regular business
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hours, by arranging with the contact
person identified below.
FOR FURTHER INFORMATION CONTACT:
Jennifer Sheehy, Deputy Assistant
Secretary, Office of Disability
Employment Policy, U.S. Department of
Labor, 200 Constitution Avenue NW.,
S–1303, Washington, DC 20210, (202)
693–7880, or visit https://www.dol.gov/
dol/contact/contactphonecallcenter.htm (TTY), for
information about this notice.
SUPPLEMENTARY INFORMATION:
Purpose
Millions of American workers leave
the workforce each year after
experiencing an injury or illness.1
Hundreds of thousands of these workers
go on to receive state or Federal
disability benefits.2 Many injured or ill
workers could remain in their jobs or
the workforce if they received timely,
effective supports.
This request for information (RFI)
offers interested parties—including but
not limited to states, community-based
and other non-profit organizations,
philanthropic organizations,
researchers, employers, health care
providers with assorted training and
specialties, private disability insurance
providers, vocational rehabilitation
specialists, and members of the public—
the opportunity to provide information
and recommendations to inform the
development of a potential grant
program aimed at reducing long-term
disability and increasing labor force
participation among workers who are
injured or become ill while employed.
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Background
The President’s 2018 budget supports
a demonstration to test promising Stayat-Work/Return-to-Work (SAW/RTW)
strategies aimed at improving labor
force participation, employment, and
earnings outcomes for workers who are
injured or become ill.
The proposed demonstration program
is modeled after promising programs in
Washington State including the Centers
for Occupational Health and Education
(COHE) 3 and the Early Return to Work 4
1 Bardos, Maura, Hannah Burak, and Yonatan
Ben-Shalom. ‘‘Assessing the Costs and Benefits of
Return-to-Work Programs.’’ Final report submitted
to the U.S. Department of Labor, Office of Disability
Employment Policy. Washington, DC: Mathematica
Policy Research, March 2015.
2 Social Security Administration, ‘‘Annual
Statistical Report on the Social Security Disability
Insurance Program, 2015.’’ SSA Publication No. 13–
11826. Washington, DC: Social Security
Administration, October 2016.
3 https://www.lni.wa.gov/ClaimsIns/Providers/
ProjResearchComm/OHS/default.asp.
4 https://www.lni.wa.gov/ClaimsIns/Insurance/
Injury/LightDuty/Ertw/Default.asp.
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(ERTW) and Stay at Work programs.5
Projects funded through the proposed
demonstration project, however, would
include additional connections to
existing employment services and
supports provided through the
workforce development system.
COHE, which is funded by
Washington’s workers’ compensation
system, provides early intervention and
RTW services for individuals with
work-related health conditions. An
evaluation of the COHE pilot in the
early 2000s produced promising results:
COHE participants were less likely to be
off work and on disability benefits one
year after the claim, and combined
medical and disability costs were
reduced by $510 per claim for COHE
participants. The magnitude of these
reductions was greater for back sprain
cases (a common occupational injury):
the relative risk of being off work and
on disability at one year was 37 percent
lower for back sprain COHE patients,
and disability costs for back sprains
were reduced by $542 per case.6
Preliminary analysis indicated that at
the eight-year mark, 26 percent fewer
COHE claimants received Social
Security Disability Insurance (SSDI)
benefits.7
The ERTW program and Stay at Work
programs in Washington State provide
related assistance. The ERTW program
helps injured and ill workers RTW as
soon as medically possible by providing
access to a team of vocational services
consultants, therapists, and nurse
consultants to assist with developing
and implementing medically
appropriate RTW options. The Stay at
Work program is a financial incentive
program that reimburses employers for
some of their costs when providing
temporary, light-duty jobs for injured
workers while they heal.
This demonstration will draw from
and test key features of the Washington
COHE model and ERTW and Stay at
Work programs, in other states and/or
for a population beyond workers’
compensation (i.e., for non-occupational
injuries and illnesses). To do that, we
anticipate funding states to operate one
or more COHE-style programs, or fund
the expansion of existing programs,
5 https://lni.wa.gov/Main/StayAtWork/.
6 Wickizer, T.M., Franklin, G., Fulton-Kehoe, D.,
Gluck, J., Mootz, R., Smith-Weller, T., and PlaegerBrockway, R. (2011) ‘‘Improving Quality,
Preventing Disability and Reducing Costs in
Workers’ Compensation Healthcare: A Populationbased Intervention Study.’’ Medical Care, Vol. 49,
No. 12, pp. 1105–1111.
7 Franklin, G.M., Wickizer, T.M., Coe, N.B, and
Fulton-Kehoe, D. (2015) ‘‘Workers’ Compensation:
Poor Quality Health Care and the Growing
Disability Problem in the United States.’’ American
Journal of Industrial Medicine, 58: 245–251.
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with an increased emphasis on access to
employment-related supports. The
ultimate policy goal is to increase
employment and labor force
participation of individuals with work
disabilities, and to identify and/or
confirm effective strategies for doing so.
For the purposes of this RFI, the term
‘‘work disability’’ is defined as an
illness, injury, or medical condition that
is anticipated to inhibit or prevent
continued employment or labor force
participation.
This RFI offers interested parties the
opportunity to provide
recommendations on effective
approaches for the design and
implementation of the demonstration
project. We expect that public input
provided in response to this request will
assist us in defining the scope and
design of the demonstration project. For
example, a demonstration project could
test whether elements of the COHE
workers’ compensation model, which
focus on immediate or early
intervention, could be combined with
re-employment services provided
through the American Job Centers for
the subset of participants who do not
return to work within 90 days so that
they could obtain additional
employment services and supports to
maintain a workforce attachment. The
RFI specifically seeks public input on
how the proposed demonstration
projects can best be designed to promote
labor force attachment, coordinate
employment and health services, and
support injured and ill workers in
returning to and remaining at work.
Background on the COHE model and
Early Return to Work and Stay at Work
programs:
As the proposed demonstration is
based on elements from Washington
State’s COHE, ERTW, and Stay at Work
programs, the following background
material is provided about these
programs. There are six COHE centers
across the state of Washington,
including some housed in large medical
systems and others that are communitybased. Each of these centers 8 recruits
and trains health care providers in their
area—often orthopedists or other
doctors specializing in treating workers’
compensation (WC) patients. COHE
started as a small pilot in two regions
and has grown to currently include
about 3,500 health care providers who
cover about 60 percent of all WC claims
in the state. Injured workers retain
health care provider choice. They
8 Grantees will not be required to establish a
‘‘center’’ or new entity as part of the demonstration.
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receive COHE services if they choose a
COHE-affiliated provider for their care.
Given that health care providers often
see relatively few patients who are at
risk of labor force separation due to
their illness or injury, many may have
limited knowledge and resources to
address the employment-related needs
of this population. Health care providers
affiliated with COHE, however, receive
training in occupational health best
practices for these cases, including the
following four best practices:
1. Submitting a complete Report of
Accident (ROA) in two business days or
less;
2. Developing an activity plan, which
communicates the worker’s ability to
participate in work activities, activity
restrictions, and the provider’s
treatment plans;
3. Communicating directly with
employers when injured workers are
absent or expected to be absent from
work; and
4. Assessing the injured worker’s
barriers to return to work and
developing a plan to overcome them.
Health service coordinators are
integral to the success of the COHE
model. The program is based on the
MacColl chronic care model.9
Successful health service coordinators
are skilled in vocational rehabilitation
and motivational interviewing and work
directly with injured workers,
employers, health care providers, and
other stakeholders to coordinate care
and RTW activities for injured workers.
They also help stakeholders navigate the
workers’ compensation system by
performing claim coordination
functions, such as ensuring forms are
received and complete and contacting
stakeholders as needed for clarifications
or follow-up. Health service
coordinators frequently contact injured
workers, employers, health care
providers, state agency staff, and other
stakeholders to help with the RTW
process, and identify barriers to
returning to work and resources to
resolve them. The RTW activities they
coordinate for the patient can include
functional assessments, referrals to
existing training and employment
services, and setting appropriate RTW
expectations. Health service
coordinators also educate employers on
the financial and other benefits of
retaining injured workers and can refer
employers to the ERTW and Stay at
Work programs for resources and
financial incentives to help them with
job accommodation. The health service
coordinators monitor all cases, but focus
9 See https://www.improvingchroniccare.org/
index.php?p=The_Chronic_Care_Model&s=2.
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on those at risk for long-term disability,
typically less than a quarter of all cases.
The health service coordinator role is
critical and depends heavily on the
neutrality of health service coordinators
in helping the health care and RTW
system work effectively for patients,
employers, health care providers, and
the insurer. This neutrality allows
health service coordinators to be trusted
by the various stakeholders, allowing
health service coordinators to maximize
the likelihood of the best-case recovery
and employment outcome.
As a program based in the medical
system, COHE depends heavily on
project champions among sponsoring
health care organizations’ leadership to
create organizational buy-in and
support. Additionally, each COHE
participates in a Regional BusinessLabor Advisory Board that ensures
community support and solicits input
from local business and labor interests.
Key features of the COHE model of
interest to the proposed demonstration
include:
1. Coordination of services, including
enhanced stakeholder communication,
RTW planning, and identification of
potential delays and solutions to keep
treatment and RTW plans on track;
2. Physician training on occupational
health best practices;
3. Incentives for physicians to utilize
the best practices for participating
patients;
4. A data management system
allowing services coordinators real-time
access to all relevant information on
each case to support effective triage,
population monitoring, and case
management.
The ERTW program helps injured and
ill workers RTW as soon as medically
possible by providing access to a team
of specialists including vocational
services consultants, therapist
consultants, and nurse consultants who
assist health care providers and
employers develop and implement
medically appropriate RTW options.
Resources available to employers
include risk management specialists,
safety consultants to provide on-site
consultations, and job modification
funds. By providing these resources, the
ERTW program speeds the worker’s
recovery and reduces the financial
impact of a workers’ compensation
claim on the worker, the employer, and
the workers’ compensation system.
The Stay at Work program
incentivizes employers to offer
temporary light-duty work to injured
employees while they heal, by
reimbursing the employers for some of
the costs of providing such jobs. Eligible
employers can be reimbursed for 50
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percent of the base wages they pay the
injured worker and some of the cost of
training, tools, or clothing the worker
needs to do the light-duty or transitional
work.
The COHE model focuses services on
the first 12 weeks after injury because
this period is most critical in
maximizing the likelihood of RTW.
While the proposed demonstration
builds upon the COHE model and the
ERTW and Stay at Work programs, it
differs from the original model by
adding an extended focus on
employment services and supports and
a strong and purposeful involvement of
the workforce development system.
Potential Project Scope
DOL and SSA anticipate three
acquisitions for this project:
Implementation grants awarded via a
cooperative agreement, a technical
assistance contract to support grantees,
and an evaluation contract. The
agencies anticipate implementing the
demonstration in two to three states
representing diverse programmatic
contexts and with the ability to provide
meaningful analyses and policy
recommendations. There would be a
separate technical assistance (TA)
contract to assist states with
implementation and a separate
integrated evaluation contract to
evaluate all of the sites and address
specific research goals. For the purposes
of this RFI, the implementation grantees
are referred to as the ‘‘projects,’’ the
technical assistance contractor is
referred to as the ‘‘TA provider,’’ and
the evaluation contractor is referred to
as the ‘‘evaluator.’’
We anticipate designing this
demonstration to solicit innovative
projects that create systems changes by
targeting individuals when they are in
the early stages of developing a work
disability, and assisting them in
maintaining a connection to the labor
force, preferably through their current or
most recent employer. Projects will be
encouraged to build upon existing
programs or systems, such as state-based
temporary disability insurance (TDI)
programs, collaborative health care
organizations, disability management
insurance providers, or workers’
compensation programs. We would also
encourage projects to think broadly
about new and effective ways to prevent
the development of long-term work
disability. The solicitation will leave
flexibility for applicants to develop their
own projects that adapt to the specific
programmatic, demographic, and
economic contexts of their state or
region while also satisfying the project’s
requirements.
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Preliminary required design elements
of the demonstration are described
below. We encourage public input and
comment on these elements in response
to the questions in the following
section.
Overview: We anticipate funding
implementation grants in two to three
states to either operate one or more
projects with key elements drawn from
the COHE model and the ERTW and
Stay at Work programs, with an added
emphasis on access to employmentrelated services and supports, or the
expansion of similar existing programs
to include increased access to
employment-related supports and
services. The ultimate policy goal is to
increase employment and labor force
participation of individuals with work
disabilities through timely and effective
coordination of health care and
employment-related services. Each
grantee would be responsible for
identifying, recruiting, and training
health care providers within their
geographic area, and incentivizing their
use of occupational health best practices
for eligible workers. In addition, each
grantee would be responsible for
providing and supporting return to work
service coordinators who will
coordinate and facilitate the RTW
process for eligible workers. Grantees
would also be responsible for providing
a centralized data collection and
reporting system for the efficient
management of the care and RTW
coordination system, and to support the
evaluation of the program.
We anticipate requiring funded
projects to include the following
treatment elements:
• Coordination of services, including
enhanced stakeholder communication,
RTW planning, and identification of
potential delays and solutions to keep
treatment and RTW plans on track;
• Health care provider training on
occupational health best practices that
COHE uses;
• Incentives for health care providers
to utilize the specified best practices for
participating patients;
• Possible incentives for employers to
actively participate in worker retention
and other RTW efforts through
utilization of strategies such as
temporary light-duty jobs, job
modifications, and job-banking;
• Provision of, or facilitated access to,
employment-related services and
supports (such as needs assessments,
skill assessments, accommodations, job
coaching, job search assistance if not
remaining with original employer) and
training;
• Engaging key stakeholders (e.g., the
business community, labor
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representatives) up front and on an
ongoing basis; and
• A data management system that:
Æ (1) allows service coordinators realtime access to all relevant information
on each case for purposes of triage,
individual case management, and
population health monitoring, including
on disability time loss duration; and
Æ (2) supports the evaluation of the
project.
Eligible grant applicants: We
anticipate requiring each project and
application to have a state agency
designated as the lead coordinating
entity. The lead agency would be
required or encouraged to form
partnerships with other public or
private organizations, such as DOLfunded employment-service providers,
state vocational rehabilitation agencies,
private non-profit organizations, health
care providers/organizations, other
public or private organizations, state
and local Workforce Investment Boards,
and county or municipal-level
governments as appropriate.
Population: Each project would be
required to identify and clearly define
its target population, including showing
that the population has a substantial
risk of developing a long-term work
disability, and/or transitioning to Social
Security Disability Insurance (SSDI) or
Supplemental Security Income (SSI),
such that the intervention could change
their employment outcomes. Projects
are encouraged to include workers with
active state TDI or workers’
compensation claims, or those using
paid leave, as well as broader
populations of workers experiencing the
onset of a medical condition that could
result in a work disability. The target
population must be clearly identifiable
using existing administrative records,
easily completed screening forms, or an
information management system, and
there must be a clear mechanism that
triggers the start of services.
Participant Recruitment: Each grantee
would propose a recruitment plan for
outreach and enrollment of worker
participants based on their target
population and their project design.
Grantees would be required to be able
to recruit a sufficient number of worker
participants to allow for a meaningful
assessment of the impact of the
intervention. Applicants would also be
required to recruit and have signed
MOUs or letters of intent with project
partners, including partnering health
care providers.
Evaluation Design: We anticipate
carrying out an impact and
implementation study to understand
how the programs are implemented,
service components, who is being
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served, the extent to which those served
experience improved outcomes
(including labor market outcomes,
receipt of SSDI/SSI), and a cost-benefit
analysis. The impact study would
include a process evaluation and
participation analysis in order to assess
the implementation and fidelity of the
program and general interest and takeup rates across the project sites. The
evaluation design would be finalized
once the evaluator is secured and would
take into account the specifics of the
funded projects. All projects would be
required to fully cooperate with and
participate in the evaluation.
Data collection: Projects would be
required to provide for centralized data
collection to capture care management,
RTW coordination information, and
measures and outcomes of interest to
the evaluation. The evaluation
contractor would be provided access to
this data. A data management system
would be required to allow the service
coordinators and others in the
intervention to have real-time access to
all relevant information on each case in
order to effectively triage, monitor, and
intervene as needed on a timely basis.
Projects would be encouraged to use or
adapt existing centralized data systems.
Evaluation: We anticipate evaluating
projects on two primary research
questions:
• Does the intervention improve
employment outcomes compared to the
control group?
• Does the intervention reduce
application to Social Security Disability
Insurance (SSDI) or Supplemental
Security Income (SSI)?
Below are additional research
questions of interest, which may not all
be answered by the initial evaluation of
the proposed demonstration:
• Does the intervention increase labor
force participation of participating
workers?
• Does the intervention increase labor
force attachment of participating
workers?
• Does the intervention reduce labor
force exit of participating workers?
• Does the intervention maintain or
result in increased wages of
participating workers?
• Does the intervention improve the
ability of participating workers to
maintain hours of work?
• Does the intervention reduce
medical, time lost, or litigation costs?
• What are optimal and efficient
methods to identify target populations
at risk of exiting the labor force that will
benefits from the intervention?
• What is the best timing to engage a
worker effectively while also
minimizing cost?
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• What recruitment methods are most
effective to engage a target population?
• Does the intervention decrease SSDI
or SSI allowance rates?
• What elements of the intervention
are most influential in determining
success (i.e., improved employment
outcomes and reduced need for SSDI or
SSI benefits)?
• What environmental factors are
necessary for successful implementation
of the intervention?
• What are the cost effective and
efficient interventions that reduce
workers exit from the labor force?
• What are the effective and efficient
strategies to incentivize employers to
actively retain workers with injuries and
health conditions?
• What are effective and efficient
strategies to create buy-in from health
care providers that work is an important
health care outcome?
Request for Information
This request for information (RFI)
seeks public input on how the proposed
demonstration projects can best be
designed to promote labor force
attachment, coordinate employment and
health services, and support injured and
ill workers in returning to and
remaining at work. Through this notice,
we are soliciting feedback from
interested parties on the scope and
design of a potential demonstration
project related to providing coordinated
occupational health and employment
services to individuals who become
injured or ill while employed in order
to enable them to remain in the labor
force, thereby improving their
employment and earnings outcomes and
maximizing their self-sufficiency.
Responses to this request will inform
decisions about the development,
design, and evaluation of the potential
demonstration project.
This notice is for internal planning
purposes only and should not be
construed as a solicitation or as an
obligation on the part of the Department
of Labor or any participating Federal
agencies. We ask respondents to address
the following questions, where possible,
in the context of the discussion in this
document. You do not need to address
every question and should focus on
those that relate to your expertise or
perspectives. To the extent possible,
please clearly indicate which
question(s) you address in your
response. We ask that each respondent
include the name and address of his or
her institution or affiliation, if any, and
the name, title, mailing and email
addresses, and telephone number of a
contact person for his or her institution
or affiliation, if any.
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Questions
I. Intervention Elements
1. Are there potential issues with the
treatment elements listed under
‘‘required treatment elements’’ on pages
6–7? Should any not be required? What
other elements might be useful, and
what is the evidence base for them?
What additional optional services and
supports could grantees choose to
include in the model? What is the
existing evidence documenting the
effectiveness of these additional
optional services and supports?
2. What should be the required and
optional roles and responsibilities of the
RTW service coordinator in
implementing the treatment elements?
3. Where should the role of a RTW
service coordinator be housed in order
to most effectively accomplish its goals,
including an ability to maintain
neutrality? For example, should service
coordinators be employed by health care
provider networks, by the public
workforce system, by private disability
insurance providers, by employers, or
by another entity?
4. Should there be educational and/or
experience requirements for the RTW
service coordinators, such as vocational
counseling or public health
backgrounds? How should these
educational and experience
requirements parallel and differ from
those of health navigators, community
health workers, and vocational
rehabilitation counselors?
5. What specific employment-related
interventions should be required or
allowed? What evidence supports these
interventions as effective in early
intervention for these populations?
When referrals to existing employmentrelated service providers occur, will
these providers have sufficient capacity
and funding to provide services in a
timely manner to referred individuals?
6. The COHE model focuses
interventions primarily in the first 12
weeks after injury/illness (with
occasional exceptions allowing up to 26
weeks). For a demonstration such as this
requiring increased involvement of the
workforce development system, what is
the optimal timing and length of
intervention? Why, or what is the
evidence base?
7. Employment services (such as
needs assessments, skill assessments,
accommodations, job coaching, job
search assistance if not remaining with
original employer) and the public
workforce system are important
elements of the proposed demonstration
program. What is the optimal time to
provide employment services? For
example, should employment services
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be provided during the same time
window as the health care services/
coordination, or afterwards? How can
the RTW service coordinators best
facilitate the effective use of
employment services?
8. What role should employer
incentives play in this intervention? Are
there particular employer incentives
that we should consider in projects
where workers’ compensation insurance
premiums play a limited role? Are there
effective non-financial ways to engage
and incentivize employers to support
and implement SAW/RTW programs
within their workplaces?
9. What is an appropriate health care
provider payment or fee structure to
incentivize the specific occupational
health best practices and to encourage a
focus on employment as a health
outcome? Are there models other than
fee-for-service that would be
appropriate and feasible, such as basing
payments on process and/or outcome
metrics? How would these models
operate in the context of managed-care
organizations?
10. How can health systems and
health care providers be better
incentivized to consider employment a
valid health outcome? What is the
recent relevant evidence documenting
the effectiveness of incentive models
(including financial or other incentives)
that include employment as an
outcome?
II. Target Population and Sites
11. What is an appropriate age range
of participants to target for this
demonstration project? For example,
should the demonstration projects target
prime-age workers (25–54)? Why or why
not?
12. What populations of RTW
participants—such as those listed
below—should be allowed, encouraged,
or required in the demonstration? Why
should the populations you recommend
be included? Are there populations of
RTW participants that you would not
recommend?
D Individuals with active state-based
TDI claims?
D Workers accessing FMLA benefits
(except for pregnancy and caring for
others)?
D Individuals with active WC claims?
D Others (not participating in WC or
TDI) experiencing the onset of a medical
condition that could affect their
connection to the workforce?
13. How should the target population
described above be specifically defined
and cleanly identified? We are
particularly interested in how to define
an appropriate population that is not
limited to individuals with state-based
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TDI claims or WC. What are the most
appropriate eligibility criteria (such as
time off work, type of condition, type of
employment) to identify such
individuals? What kinds of ‘‘triggers’’
would work for the population as a
mechanism for enrollment into the
project?
14. Are there specific functional risk
assessment instruments that you
recommend using for this project? What
are the benefits and limitations of those
instruments? How might they be used to
identify the target population here or
form the basis for an RTW plan?
15. Are there aspects of your state’s
TDI, paid leave, FMLA, WC, or other
state programs that would pose
particular advantages or challenges for
identifying workers who might benefit
from an intervention like the one
discussed above? Are there aspects of
these programs that would pose
particular advantages or challenges for
collecting data on treatments, services,
and outcomes for a project like this?
16. Should the target population be
limited to individuals with certain types
of medical conditions, such as
musculoskeletal conditions and chronic
health conditions? Why or why not?
17. How should project service areas
be defined? For example, should
demonstrations be carried out statewide, in specific counties, regions, or
local communities? Would these service
areas have a large enough target
population for evaluation purposes?
18. What types of entities would be
the most beneficial to consider
partnering with to provide the COHEstyle services, and why? Examples
could include large health-care systems,
collections of small health care provider
offices, private self-insured employers
with in-house disability management,
vocational rehabilitation providers,
accountable or managed care
organizations, federally qualified
community health centers, community
based organizations, and urgent care
centers.
III. Eligible Applicants
19. What types of state government
entities are the most logical or wellpositioned to serve as the primary
applicant and fiscal agent? What is the
best way to organize the structure of a
demonstration like the one described
above in your state? What structure
would best enable effective leadership,
responsibility, and accountability for
the project? Would a single agency be
the natural lead for the project?
20. Similar state functions may be
housed in different agencies, depending
on the state. Should key functions be
required, rather than specific agencies?
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If so, what functions should be
required?
21. Should groups of states be allowed
to jointly apply? Why or why not?
22. Could a non-state (i.e., county or
local government) or non-governmental
(i.e., non-profit or private organization)
entity serve as the primary applicant
and fiscal agent? If so, what
characteristics should be required of
such entities? Would this be preferable
to a state governmental agency serving
in this role? Why or why not?
23. The COHE model in Washington
operates within a monopolistic WC
system, which allows for centralized
participant controls, service
management, and data collection.
Would states with other WC models,
such as privately managed and
competitive WC markets, be able to
feasibly implement a similar model,
particularly with regard to data
collection? If so, how? Would states
with short-term or temporary disability
insurance programs or states with
mandatory paid sick leave be able to do
so, and how? In other words, should
grant applicants be limited to states
with specific characteristics, and why or
why not?
24. What partners, public or private,
should be required or encouraged as
part of the demonstration project? What
other entities might be beneficial as
collaborators? In what ways could they
assist?
IV. Evaluation and Design Issues
25. Are there research questions, not
specified above, that could be answered
through the evaluation which would
improve understanding of ways to better
serve and increase employment and
labor force participation of individuals
with work disabilities?
26. What entity would be most
successful in recruiting participants
who have a qualifying injury or health
condition (that makes them at risk for
leaving the labor force)? Examples could
include an insurance company, state
TDI or WC insurance providers, an
employer, or a health care provider.
27. Do health systems and/or health
care providers utilize risk predictors to
target specific types of services? If so,
which predictors are used, and for
which services? Are any employmentor SAW/RTW-related?
28. If a cluster-randomized design is
used for an experimental impact
evaluation, how could the unit of
randomization be defined and
operationalized within various types of
grantee sites? Are there other evaluation
designs (randomized or not) that would
be more feasible (e.g. quasiexperimental design)? If so, how could
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45623
a potential comparison group be
identified? If other randomized designs
are recommended, what are potential
units for random assignment and points
at which assignment would occur?
Rights to Materials Submitted
By submitting material in response to
this notice, you agree to grant us a
worldwide, royalty-free, perpetual,
irrevocable, nonexclusive license to use
the material, and to post it publicly.
Further, you agree that you own, have
a valid license, or are otherwise
authorized to provide the material to us.
You should not provide any material
you consider confidential or proprietary
in response to this notice. We will not
provide any compensation for material
submitted in response to this notice.
Jennifer Sheehy,
Deputy Assistant Secretary for Disability
Employment Policy.
[FR Doc. 2017–20338 Filed 9–28–17; 8:45 am]
BILLING CODE P
LEGAL SERVICES CORPORATION
Notice to LSC Grantees of Application
Process for Subgranting 2017–2018
Pro Bono Innovation Fund and
Technology Initiative Grant Funds
Legal Services Corporation.
Notice of application dates and
format for LSC Technology Initiative
Grants and Pro Bono Innovation Fund
subgrant applications.
AGENCY:
ACTION:
The Legal Services
Corporation (LSC) announces the
submission dates for applications for
subgrants under its Technology
Initiative Grants and its Pro Bono
Innovation Fund grants starting after
October 30, 2017. LSC is also providing
information about the location of
subgrant application forms and
directions.
DATES: See SUPPLEMENTARY INFORMATION
section for application dates.
ADDRESSES: Legal Services
Corporation—Office of Compliance and
Enforcement, 3333 K Street NW., Third
Floor, Washington, DC 20007–3522.
FOR FURTHER INFORMATION CONTACT:
Office of Compliance and Enforcement
by email at subgrants@lsc.gov, or visit
the LSC Web site at https://www.lsc.gov/
grants-grantee-resources/granteeguidance/how-apply-subgrant.
SUPPLEMENTARY INFORMATION: LSC
revised its subgrant rule, 45 CFR part
1627, effective April 1, 2017. The
revised rule requires LSC to publish, on
an annual basis, ‘‘notice of the
requirements concerning the format and
SUMMARY:
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Agencies
[Federal Register Volume 82, Number 188 (Friday, September 29, 2017)]
[Notices]
[Pages 45618-45623]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2017-20338]
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DEPARTMENT OF LABOR
[Agency Docket Number: DOL-2017-0003]
Request for Information on Potential Stay-at-Work/Return-to-Work
Demonstration Projects
AGENCY: Office of Disability Employment Policy, DOL.
ACTION: Request for information.
-----------------------------------------------------------------------
SUMMARY: Washington State's workers' compensation system runs several
promising early intervention programs including the Centers of
Occupational Health and Education (COHE) and the Early Return to Work
and the Stay at Work programs, which provide early intervention and
return-to-work services for individuals with work-related health
conditions and their employers. The President's FY2018 budget proposed
that the Office of Disability Employment Policy (ODEP) at the U.S.
Department of Labor (DOL) and the Social Security Administration (SSA)
jointly conduct a demonstration testing the effects of implementing key
features of these programs in other states and/or for a broader
population beyond workers' compensation. To do that, we anticipate
funding two to three states to operate projects with key elements drawn
from the Washington State programs mentioned above, with an increased
emphasis on access to employment-related supports, or fund the
expansion of existing programs to include increased access to
employment-related supports. The ultimate policy goal is to increase
employment and labor force participation of individuals who have or are
developing work disabilities. This request for information (RFI) seeks
public input on how the proposed demonstration projects can best be
designed to promote labor force attachment, coordinate employment and
health services, and support injured and ill workers in returning to
and remaining at work. The input we receive will inform our
deliberations about the possible design of a future demonstration
project.
DATES: Comments must be received by October 30, 2017.
ADDRESSES: You may submit comments by any one of three methods--
Internet, fax, or mail. Do not submit the same comments multiple times
or by more than one method. Regardless of which method you choose,
please refer to Docket No. DOL-2017-0003in your comment pages so that
we may associate your comments with the correct docket.
Caution: In your comments, you should be careful to include only
the information that you wish to make publicly available. We strongly
urge you not to include in your comments any personal information, such
as Social Security numbers or medical information.
1. Internet: We strongly recommend that you submit your comments
via the Internet. Please visit the Federal eRulemaking portal at https://www.regulations.gov. Use the ``Search'' function to find docket number
DOL-2017-0003. The system will issue a tracking number to confirm your
submission. You will not be able to view your comment immediately
because we must post each comment manually. It may take up to a week
for your comment to be viewable.
2. Fax: Fax comments to (202) 693-7888.
3. Mail: Mail your comments to the Office of Disability Employment
Policy, U.S. Department of Labor, 200 Constitution Avenue NW., S-1303,
Washington, DC 20210.
Comments are available for public viewing on the Federal
eRulemaking portal at https://www.regulations.gov or in person, during
regular business
[[Page 45619]]
hours, by arranging with the contact person identified below.
FOR FURTHER INFORMATION CONTACT: Jennifer Sheehy, Deputy Assistant
Secretary, Office of Disability Employment Policy, U.S. Department of
Labor, 200 Constitution Avenue NW., S-1303, Washington, DC 20210, (202)
693-7880, or visit https://www.dol.gov/dol/contact/contact-phonecallcenter.htm (TTY), for information about this notice.
SUPPLEMENTARY INFORMATION:
Purpose
Millions of American workers leave the workforce each year after
experiencing an injury or illness.\1\ Hundreds of thousands of these
workers go on to receive state or Federal disability benefits.\2\ Many
injured or ill workers could remain in their jobs or the workforce if
they received timely, effective supports.
---------------------------------------------------------------------------
\1\ Bardos, Maura, Hannah Burak, and Yonatan Ben-Shalom.
``Assessing the Costs and Benefits of Return-to-Work Programs.''
Final report submitted to the U.S. Department of Labor, Office of
Disability Employment Policy. Washington, DC: Mathematica Policy
Research, March 2015.
\2\ Social Security Administration, ``Annual Statistical Report
on the Social Security Disability Insurance Program, 2015.'' SSA
Publication No. 13-11826. Washington, DC: Social Security
Administration, October 2016.
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This request for information (RFI) offers interested parties--
including but not limited to states, community-based and other non-
profit organizations, philanthropic organizations, researchers,
employers, health care providers with assorted training and
specialties, private disability insurance providers, vocational
rehabilitation specialists, and members of the public--the opportunity
to provide information and recommendations to inform the development of
a potential grant program aimed at reducing long-term disability and
increasing labor force participation among workers who are injured or
become ill while employed.
Background
The President's 2018 budget supports a demonstration to test
promising Stay-at-Work/Return-to-Work (SAW/RTW) strategies aimed at
improving labor force participation, employment, and earnings outcomes
for workers who are injured or become ill.
The proposed demonstration program is modeled after promising
programs in Washington State including the Centers for Occupational
Health and Education (COHE) \3\ and the Early Return to Work \4\ (ERTW)
and Stay at Work programs.\5\ Projects funded through the proposed
demonstration project, however, would include additional connections to
existing employment services and supports provided through the
workforce development system.
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\3\ https://www.lni.wa.gov/ClaimsIns/Providers/ProjResearchComm/OHS/default.asp.
\4\ https://www.lni.wa.gov/ClaimsIns/Insurance/Injury/LightDuty/Ertw/Default.asp.
\5\ https://lni.wa.gov/Main/StayAtWork/.
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COHE, which is funded by Washington's workers' compensation system,
provides early intervention and RTW services for individuals with work-
related health conditions. An evaluation of the COHE pilot in the early
2000s produced promising results: COHE participants were less likely to
be off work and on disability benefits one year after the claim, and
combined medical and disability costs were reduced by $510 per claim
for COHE participants. The magnitude of these reductions was greater
for back sprain cases (a common occupational injury): the relative risk
of being off work and on disability at one year was 37 percent lower
for back sprain COHE patients, and disability costs for back sprains
were reduced by $542 per case.\6\ Preliminary analysis indicated that
at the eight-year mark, 26 percent fewer COHE claimants received Social
Security Disability Insurance (SSDI) benefits.\7\
---------------------------------------------------------------------------
\6\ Wickizer, T.M., Franklin, G., Fulton-Kehoe, D., Gluck, J.,
Mootz, R., Smith-Weller, T., and Plaeger-Brockway, R. (2011)
``Improving Quality, Preventing Disability and Reducing Costs in
Workers' Compensation Healthcare: A Population-based Intervention
Study.'' Medical Care, Vol. 49, No. 12, pp. 1105-1111.
\7\ Franklin, G.M., Wickizer, T.M., Coe, N.B, and Fulton-Kehoe,
D. (2015) ``Workers' Compensation: Poor Quality Health Care and the
Growing Disability Problem in the United States.'' American Journal
of Industrial Medicine, 58: 245-251.
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The ERTW program and Stay at Work programs in Washington State
provide related assistance. The ERTW program helps injured and ill
workers RTW as soon as medically possible by providing access to a team
of vocational services consultants, therapists, and nurse consultants
to assist with developing and implementing medically appropriate RTW
options. The Stay at Work program is a financial incentive program that
reimburses employers for some of their costs when providing temporary,
light-duty jobs for injured workers while they heal.
This demonstration will draw from and test key features of the
Washington COHE model and ERTW and Stay at Work programs, in other
states and/or for a population beyond workers' compensation (i.e., for
non-occupational injuries and illnesses). To do that, we anticipate
funding states to operate one or more COHE-style programs, or fund the
expansion of existing programs, with an increased emphasis on access to
employment-related supports. The ultimate policy goal is to increase
employment and labor force participation of individuals with work
disabilities, and to identify and/or confirm effective strategies for
doing so. For the purposes of this RFI, the term ``work disability'' is
defined as an illness, injury, or medical condition that is anticipated
to inhibit or prevent continued employment or labor force
participation.
This RFI offers interested parties the opportunity to provide
recommendations on effective approaches for the design and
implementation of the demonstration project. We expect that public
input provided in response to this request will assist us in defining
the scope and design of the demonstration project. For example, a
demonstration project could test whether elements of the COHE workers'
compensation model, which focus on immediate or early intervention,
could be combined with re-employment services provided through the
American Job Centers for the subset of participants who do not return
to work within 90 days so that they could obtain additional employment
services and supports to maintain a workforce attachment. The RFI
specifically seeks public input on how the proposed demonstration
projects can best be designed to promote labor force attachment,
coordinate employment and health services, and support injured and ill
workers in returning to and remaining at work.
Background on the COHE model and Early Return to Work and Stay at
Work programs:
As the proposed demonstration is based on elements from Washington
State's COHE, ERTW, and Stay at Work programs, the following background
material is provided about these programs. There are six COHE centers
across the state of Washington, including some housed in large medical
systems and others that are community-based. Each of these centers \8\
recruits and trains health care providers in their area--often
orthopedists or other doctors specializing in treating workers'
compensation (WC) patients. COHE started as a small pilot in two
regions and has grown to currently include about 3,500 health care
providers who cover about 60 percent of all WC claims in the state.
Injured workers retain health care provider choice. They
[[Page 45620]]
receive COHE services if they choose a COHE-affiliated provider for
their care.
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\8\ Grantees will not be required to establish a ``center'' or
new entity as part of the demonstration.
---------------------------------------------------------------------------
Given that health care providers often see relatively few patients
who are at risk of labor force separation due to their illness or
injury, many may have limited knowledge and resources to address the
employment-related needs of this population. Health care providers
affiliated with COHE, however, receive training in occupational health
best practices for these cases, including the following four best
practices:
1. Submitting a complete Report of Accident (ROA) in two business
days or less;
2. Developing an activity plan, which communicates the worker's
ability to participate in work activities, activity restrictions, and
the provider's treatment plans;
3. Communicating directly with employers when injured workers are
absent or expected to be absent from work; and
4. Assessing the injured worker's barriers to return to work and
developing a plan to overcome them.
Health service coordinators are integral to the success of the COHE
model. The program is based on the MacColl chronic care model.\9\
Successful health service coordinators are skilled in vocational
rehabilitation and motivational interviewing and work directly with
injured workers, employers, health care providers, and other
stakeholders to coordinate care and RTW activities for injured workers.
They also help stakeholders navigate the workers' compensation system
by performing claim coordination functions, such as ensuring forms are
received and complete and contacting stakeholders as needed for
clarifications or follow-up. Health service coordinators frequently
contact injured workers, employers, health care providers, state agency
staff, and other stakeholders to help with the RTW process, and
identify barriers to returning to work and resources to resolve them.
The RTW activities they coordinate for the patient can include
functional assessments, referrals to existing training and employment
services, and setting appropriate RTW expectations. Health service
coordinators also educate employers on the financial and other benefits
of retaining injured workers and can refer employers to the ERTW and
Stay at Work programs for resources and financial incentives to help
them with job accommodation. The health service coordinators monitor
all cases, but focus on those at risk for long-term disability,
typically less than a quarter of all cases. The health service
coordinator role is critical and depends heavily on the neutrality of
health service coordinators in helping the health care and RTW system
work effectively for patients, employers, health care providers, and
the insurer. This neutrality allows health service coordinators to be
trusted by the various stakeholders, allowing health service
coordinators to maximize the likelihood of the best-case recovery and
employment outcome.
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\9\ See https://www.improvingchroniccare.org/index.php?p=The_Chronic_Care_Model&s=2.
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As a program based in the medical system, COHE depends heavily on
project champions among sponsoring health care organizations'
leadership to create organizational buy-in and support. Additionally,
each COHE participates in a Regional Business-Labor Advisory Board that
ensures community support and solicits input from local business and
labor interests.
Key features of the COHE model of interest to the proposed
demonstration include:
1. Coordination of services, including enhanced stakeholder
communication, RTW planning, and identification of potential delays and
solutions to keep treatment and RTW plans on track;
2. Physician training on occupational health best practices;
3. Incentives for physicians to utilize the best practices for
participating patients;
4. A data management system allowing services coordinators real-
time access to all relevant information on each case to support
effective triage, population monitoring, and case management.
The ERTW program helps injured and ill workers RTW as soon as
medically possible by providing access to a team of specialists
including vocational services consultants, therapist consultants, and
nurse consultants who assist health care providers and employers
develop and implement medically appropriate RTW options. Resources
available to employers include risk management specialists, safety
consultants to provide on-site consultations, and job modification
funds. By providing these resources, the ERTW program speeds the
worker's recovery and reduces the financial impact of a workers'
compensation claim on the worker, the employer, and the workers'
compensation system.
The Stay at Work program incentivizes employers to offer temporary
light-duty work to injured employees while they heal, by reimbursing
the employers for some of the costs of providing such jobs. Eligible
employers can be reimbursed for 50 percent of the base wages they pay
the injured worker and some of the cost of training, tools, or clothing
the worker needs to do the light-duty or transitional work.
The COHE model focuses services on the first 12 weeks after injury
because this period is most critical in maximizing the likelihood of
RTW. While the proposed demonstration builds upon the COHE model and
the ERTW and Stay at Work programs, it differs from the original model
by adding an extended focus on employment services and supports and a
strong and purposeful involvement of the workforce development system.
Potential Project Scope
DOL and SSA anticipate three acquisitions for this project:
Implementation grants awarded via a cooperative agreement, a technical
assistance contract to support grantees, and an evaluation contract.
The agencies anticipate implementing the demonstration in two to three
states representing diverse programmatic contexts and with the ability
to provide meaningful analyses and policy recommendations. There would
be a separate technical assistance (TA) contract to assist states with
implementation and a separate integrated evaluation contract to
evaluate all of the sites and address specific research goals. For the
purposes of this RFI, the implementation grantees are referred to as
the ``projects,'' the technical assistance contractor is referred to as
the ``TA provider,'' and the evaluation contractor is referred to as
the ``evaluator.''
We anticipate designing this demonstration to solicit innovative
projects that create systems changes by targeting individuals when they
are in the early stages of developing a work disability, and assisting
them in maintaining a connection to the labor force, preferably through
their current or most recent employer. Projects will be encouraged to
build upon existing programs or systems, such as state-based temporary
disability insurance (TDI) programs, collaborative health care
organizations, disability management insurance providers, or workers'
compensation programs. We would also encourage projects to think
broadly about new and effective ways to prevent the development of
long-term work disability. The solicitation will leave flexibility for
applicants to develop their own projects that adapt to the specific
programmatic, demographic, and economic contexts of their state or
region while also satisfying the project's requirements.
[[Page 45621]]
Preliminary required design elements of the demonstration are
described below. We encourage public input and comment on these
elements in response to the questions in the following section.
Overview: We anticipate funding implementation grants in two to
three states to either operate one or more projects with key elements
drawn from the COHE model and the ERTW and Stay at Work programs, with
an added emphasis on access to employment-related services and
supports, or the expansion of similar existing programs to include
increased access to employment-related supports and services. The
ultimate policy goal is to increase employment and labor force
participation of individuals with work disabilities through timely and
effective coordination of health care and employment-related services.
Each grantee would be responsible for identifying, recruiting, and
training health care providers within their geographic area, and
incentivizing their use of occupational health best practices for
eligible workers. In addition, each grantee would be responsible for
providing and supporting return to work service coordinators who will
coordinate and facilitate the RTW process for eligible workers.
Grantees would also be responsible for providing a centralized data
collection and reporting system for the efficient management of the
care and RTW coordination system, and to support the evaluation of the
program.
We anticipate requiring funded projects to include the following
treatment elements:
Coordination of services, including enhanced stakeholder
communication, RTW planning, and identification of potential delays and
solutions to keep treatment and RTW plans on track;
Health care provider training on occupational health best
practices that COHE uses;
Incentives for health care providers to utilize the
specified best practices for participating patients;
Possible incentives for employers to actively participate
in worker retention and other RTW efforts through utilization of
strategies such as temporary light-duty jobs, job modifications, and
job-banking;
Provision of, or facilitated access to, employment-related
services and supports (such as needs assessments, skill assessments,
accommodations, job coaching, job search assistance if not remaining
with original employer) and training;
Engaging key stakeholders (e.g., the business community,
labor representatives) up front and on an ongoing basis; and
A data management system that:
[cir] (1) allows service coordinators real-time access to all
relevant information on each case for purposes of triage, individual
case management, and population health monitoring, including on
disability time loss duration; and
[cir] (2) supports the evaluation of the project.
Eligible grant applicants: We anticipate requiring each project and
application to have a state agency designated as the lead coordinating
entity. The lead agency would be required or encouraged to form
partnerships with other public or private organizations, such as DOL-
funded employment-service providers, state vocational rehabilitation
agencies, private non-profit organizations, health care providers/
organizations, other public or private organizations, state and local
Workforce Investment Boards, and county or municipal-level governments
as appropriate.
Population: Each project would be required to identify and clearly
define its target population, including showing that the population has
a substantial risk of developing a long-term work disability, and/or
transitioning to Social Security Disability Insurance (SSDI) or
Supplemental Security Income (SSI), such that the intervention could
change their employment outcomes. Projects are encouraged to include
workers with active state TDI or workers' compensation claims, or those
using paid leave, as well as broader populations of workers
experiencing the onset of a medical condition that could result in a
work disability. The target population must be clearly identifiable
using existing administrative records, easily completed screening
forms, or an information management system, and there must be a clear
mechanism that triggers the start of services.
Participant Recruitment: Each grantee would propose a recruitment
plan for outreach and enrollment of worker participants based on their
target population and their project design. Grantees would be required
to be able to recruit a sufficient number of worker participants to
allow for a meaningful assessment of the impact of the intervention.
Applicants would also be required to recruit and have signed MOUs or
letters of intent with project partners, including partnering health
care providers.
Evaluation Design: We anticipate carrying out an impact and
implementation study to understand how the programs are implemented,
service components, who is being served, the extent to which those
served experience improved outcomes (including labor market outcomes,
receipt of SSDI/SSI), and a cost-benefit analysis. The impact study
would include a process evaluation and participation analysis in order
to assess the implementation and fidelity of the program and general
interest and take-up rates across the project sites. The evaluation
design would be finalized once the evaluator is secured and would take
into account the specifics of the funded projects. All projects would
be required to fully cooperate with and participate in the evaluation.
Data collection: Projects would be required to provide for
centralized data collection to capture care management, RTW
coordination information, and measures and outcomes of interest to the
evaluation. The evaluation contractor would be provided access to this
data. A data management system would be required to allow the service
coordinators and others in the intervention to have real-time access to
all relevant information on each case in order to effectively triage,
monitor, and intervene as needed on a timely basis. Projects would be
encouraged to use or adapt existing centralized data systems.
Evaluation: We anticipate evaluating projects on two primary
research questions:
Does the intervention improve employment outcomes compared
to the control group?
Does the intervention reduce application to Social
Security Disability Insurance (SSDI) or Supplemental Security Income
(SSI)?
Below are additional research questions of interest, which may not
all be answered by the initial evaluation of the proposed
demonstration:
Does the intervention increase labor force participation
of participating workers?
Does the intervention increase labor force attachment of
participating workers?
Does the intervention reduce labor force exit of
participating workers?
Does the intervention maintain or result in increased
wages of participating workers?
Does the intervention improve the ability of participating
workers to maintain hours of work?
Does the intervention reduce medical, time lost, or
litigation costs?
What are optimal and efficient methods to identify target
populations at risk of exiting the labor force that will benefits from
the intervention?
What is the best timing to engage a worker effectively
while also minimizing cost?
[[Page 45622]]
What recruitment methods are most effective to engage a
target population?
Does the intervention decrease SSDI or SSI allowance
rates?
What elements of the intervention are most influential in
determining success (i.e., improved employment outcomes and reduced
need for SSDI or SSI benefits)?
What environmental factors are necessary for successful
implementation of the intervention?
What are the cost effective and efficient interventions
that reduce workers exit from the labor force?
What are the effective and efficient strategies to
incentivize employers to actively retain workers with injuries and
health conditions?
What are effective and efficient strategies to create buy-
in from health care providers that work is an important health care
outcome?
Request for Information
This request for information (RFI) seeks public input on how the
proposed demonstration projects can best be designed to promote labor
force attachment, coordinate employment and health services, and
support injured and ill workers in returning to and remaining at work.
Through this notice, we are soliciting feedback from interested parties
on the scope and design of a potential demonstration project related to
providing coordinated occupational health and employment services to
individuals who become injured or ill while employed in order to enable
them to remain in the labor force, thereby improving their employment
and earnings outcomes and maximizing their self-sufficiency. Responses
to this request will inform decisions about the development, design,
and evaluation of the potential demonstration project.
This notice is for internal planning purposes only and should not
be construed as a solicitation or as an obligation on the part of the
Department of Labor or any participating Federal agencies. We ask
respondents to address the following questions, where possible, in the
context of the discussion in this document. You do not need to address
every question and should focus on those that relate to your expertise
or perspectives. To the extent possible, please clearly indicate which
question(s) you address in your response. We ask that each respondent
include the name and address of his or her institution or affiliation,
if any, and the name, title, mailing and email addresses, and telephone
number of a contact person for his or her institution or affiliation,
if any.
Questions
I. Intervention Elements
1. Are there potential issues with the treatment elements listed
under ``required treatment elements'' on pages 6-7? Should any not be
required? What other elements might be useful, and what is the evidence
base for them? What additional optional services and supports could
grantees choose to include in the model? What is the existing evidence
documenting the effectiveness of these additional optional services and
supports?
2. What should be the required and optional roles and
responsibilities of the RTW service coordinator in implementing the
treatment elements?
3. Where should the role of a RTW service coordinator be housed in
order to most effectively accomplish its goals, including an ability to
maintain neutrality? For example, should service coordinators be
employed by health care provider networks, by the public workforce
system, by private disability insurance providers, by employers, or by
another entity?
4. Should there be educational and/or experience requirements for
the RTW service coordinators, such as vocational counseling or public
health backgrounds? How should these educational and experience
requirements parallel and differ from those of health navigators,
community health workers, and vocational rehabilitation counselors?
5. What specific employment-related interventions should be
required or allowed? What evidence supports these interventions as
effective in early intervention for these populations? When referrals
to existing employment-related service providers occur, will these
providers have sufficient capacity and funding to provide services in a
timely manner to referred individuals?
6. The COHE model focuses interventions primarily in the first 12
weeks after injury/illness (with occasional exceptions allowing up to
26 weeks). For a demonstration such as this requiring increased
involvement of the workforce development system, what is the optimal
timing and length of intervention? Why, or what is the evidence base?
7. Employment services (such as needs assessments, skill
assessments, accommodations, job coaching, job search assistance if not
remaining with original employer) and the public workforce system are
important elements of the proposed demonstration program. What is the
optimal time to provide employment services? For example, should
employment services be provided during the same time window as the
health care services/coordination, or afterwards? How can the RTW
service coordinators best facilitate the effective use of employment
services?
8. What role should employer incentives play in this intervention?
Are there particular employer incentives that we should consider in
projects where workers' compensation insurance premiums play a limited
role? Are there effective non-financial ways to engage and incentivize
employers to support and implement SAW/RTW programs within their
workplaces?
9. What is an appropriate health care provider payment or fee
structure to incentivize the specific occupational health best
practices and to encourage a focus on employment as a health outcome?
Are there models other than fee-for-service that would be appropriate
and feasible, such as basing payments on process and/or outcome
metrics? How would these models operate in the context of managed-care
organizations?
10. How can health systems and health care providers be better
incentivized to consider employment a valid health outcome? What is the
recent relevant evidence documenting the effectiveness of incentive
models (including financial or other incentives) that include
employment as an outcome?
II. Target Population and Sites
11. What is an appropriate age range of participants to target for
this demonstration project? For example, should the demonstration
projects target prime-age workers (25-54)? Why or why not?
12. What populations of RTW participants--such as those listed
below--should be allowed, encouraged, or required in the demonstration?
Why should the populations you recommend be included? Are there
populations of RTW participants that you would not recommend?
[ssquf] Individuals with active state-based TDI claims?
[ssquf] Workers accessing FMLA benefits (except for pregnancy and
caring for others)?
[ssquf] Individuals with active WC claims?
[ssquf] Others (not participating in WC or TDI) experiencing the
onset of a medical condition that could affect their connection to the
workforce?
13. How should the target population described above be
specifically defined and cleanly identified? We are particularly
interested in how to define an appropriate population that is not
limited to individuals with state-based
[[Page 45623]]
TDI claims or WC. What are the most appropriate eligibility criteria
(such as time off work, type of condition, type of employment) to
identify such individuals? What kinds of ``triggers'' would work for
the population as a mechanism for enrollment into the project?
14. Are there specific functional risk assessment instruments that
you recommend using for this project? What are the benefits and
limitations of those instruments? How might they be used to identify
the target population here or form the basis for an RTW plan?
15. Are there aspects of your state's TDI, paid leave, FMLA, WC, or
other state programs that would pose particular advantages or
challenges for identifying workers who might benefit from an
intervention like the one discussed above? Are there aspects of these
programs that would pose particular advantages or challenges for
collecting data on treatments, services, and outcomes for a project
like this?
16. Should the target population be limited to individuals with
certain types of medical conditions, such as musculoskeletal conditions
and chronic health conditions? Why or why not?
17. How should project service areas be defined? For example,
should demonstrations be carried out state-wide, in specific counties,
regions, or local communities? Would these service areas have a large
enough target population for evaluation purposes?
18. What types of entities would be the most beneficial to consider
partnering with to provide the COHE-style services, and why? Examples
could include large health-care systems, collections of small health
care provider offices, private self-insured employers with in-house
disability management, vocational rehabilitation providers, accountable
or managed care organizations, federally qualified community health
centers, community based organizations, and urgent care centers.
III. Eligible Applicants
19. What types of state government entities are the most logical or
well-positioned to serve as the primary applicant and fiscal agent?
What is the best way to organize the structure of a demonstration like
the one described above in your state? What structure would best enable
effective leadership, responsibility, and accountability for the
project? Would a single agency be the natural lead for the project?
20. Similar state functions may be housed in different agencies,
depending on the state. Should key functions be required, rather than
specific agencies? If so, what functions should be required?
21. Should groups of states be allowed to jointly apply? Why or why
not?
22. Could a non-state (i.e., county or local government) or non-
governmental (i.e., non-profit or private organization) entity serve as
the primary applicant and fiscal agent? If so, what characteristics
should be required of such entities? Would this be preferable to a
state governmental agency serving in this role? Why or why not?
23. The COHE model in Washington operates within a monopolistic WC
system, which allows for centralized participant controls, service
management, and data collection. Would states with other WC models,
such as privately managed and competitive WC markets, be able to
feasibly implement a similar model, particularly with regard to data
collection? If so, how? Would states with short-term or temporary
disability insurance programs or states with mandatory paid sick leave
be able to do so, and how? In other words, should grant applicants be
limited to states with specific characteristics, and why or why not?
24. What partners, public or private, should be required or
encouraged as part of the demonstration project? What other entities
might be beneficial as collaborators? In what ways could they assist?
IV. Evaluation and Design Issues
25. Are there research questions, not specified above, that could
be answered through the evaluation which would improve understanding of
ways to better serve and increase employment and labor force
participation of individuals with work disabilities?
26. What entity would be most successful in recruiting participants
who have a qualifying injury or health condition (that makes them at
risk for leaving the labor force)? Examples could include an insurance
company, state TDI or WC insurance providers, an employer, or a health
care provider.
27. Do health systems and/or health care providers utilize risk
predictors to target specific types of services? If so, which
predictors are used, and for which services? Are any employment- or
SAW/RTW-related?
28. If a cluster-randomized design is used for an experimental
impact evaluation, how could the unit of randomization be defined and
operationalized within various types of grantee sites? Are there other
evaluation designs (randomized or not) that would be more feasible
(e.g. quasi-experimental design)? If so, how could a potential
comparison group be identified? If other randomized designs are
recommended, what are potential units for random assignment and points
at which assignment would occur?
Rights to Materials Submitted
By submitting material in response to this notice, you agree to
grant us a worldwide, royalty-free, perpetual, irrevocable,
nonexclusive license to use the material, and to post it publicly.
Further, you agree that you own, have a valid license, or are otherwise
authorized to provide the material to us. You should not provide any
material you consider confidential or proprietary in response to this
notice. We will not provide any compensation for material submitted in
response to this notice.
Jennifer Sheehy,
Deputy Assistant Secretary for Disability Employment Policy.
[FR Doc. 2017-20338 Filed 9-28-17; 8:45 am]
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