208.00P Comparable Benefits and Services

(Revised July 2017)

See corresponding policy: 208.00 Comparable Benefits and Services Policy

Note: Vocational Rehabilitation procedures provide internal guidance for ACCES-VR staff only and create no procedural or substantive rights for any individual or group.

Table of Contents


The required pursuit of comparable benefits is limited to benefits available from federal, State and local grant sources, health insurance and employee benefit programs that are applicable to services required for the successful completion of the IPE.

Sources of Comparable Benefits

Comparable benefits are to be pursued only for goods and services that are provided or paid for by:

  1. Federal, State or local public agencies. Examples would include Medicaid, Veteran's Benefits, TAP, Pell, reduced fare public transportation for individuals with disabilities, publicly funded para-transit services, etc.
  2. Health insurance, from any source.
  3. Employers. Specific examples of comparable benefits that may be offered by an employer include, but are not limited to: tuition assistance, transportation, training courses and health insurance benefits.

Services Excluded from Consideration of Comparable Benefits

Services specifically excluded from the required consideration of comparable benefits are:

  1. assessment for the purpose of determining eligibility or for determining vocational rehabilitation needs;
  2. vocational counseling, guidance and referral services;
  3. training services, except those which are part of a postsecondary program, including college, trade school, business school, nursing school, etc.;
  4. placement services; and,
  5. rehabilitation technology.

Comparable Benefits

Private scholarships or contributions from non-governmental sources are not comparable benefits under federal regulations. However, it is still appropriate to ask a participant if they are in receipt of such benefits. Comparable benefits do not include awards and scholarships based on merit.

Individuals must be advised of their responsibility to make maximum effort to secure comparable benefits as soon in the IPE development process as possible. This will ensure that comparable benefits are available at the time services are initiated.

If a delay in the receipt of comparable benefits would prevent an individual from starting a program as soon as it is available, consideration of comparable benefits may be waived as follows:

  1. The individual can demonstrate that he/she has made conscientious and timely effort in applying for comparable benefits and the delay would be for more than six months.
  2. The individual can demonstrate that he/she has made conscientious and timely effort in applying for comparable benefits and the total cost of service is less than $500.00.
  3. The District Manager or his/her designee may approve an exception to consideration of comparable benefits, if there is clear and convincing evidence that a delay would cause undue hardship to the individual.

Student Loan Default

ACCES-VR cannot pay for training or related services to post-secondary programs eligible for TAP and PELL for individuals in default of a student loan until that individual has re-established eligibility for financial aid.

Case Recording

  1. In all cases, document in the case record the comparable benefits that are available to the individual, including the date of the individual's application for benefits, the receipt or denial of benefits, and the amounts of any benefits to be received by the individual. This information can be documented in any of the following: the College Financial Aid statement, the VR-845 ACCES-VR Contribution Calculation Worksheet or in a case note, using the Comparable Benefits header or confirmation from the source of the comparable benefit.
  2. The IPE must document the amount of the comparable benefit, as it applies to each line of service. If there is no comparable benefit available to reduce the cost of the service, then the amount to enter in the comparable benefit field on the CaMS IPE service screen is 0. If there is a known comparable benefit, the amount of that known benefit must be entered in the comparable benefit field. If there is a possible comparable benefit, or a known comparable benefit but the specific dollar value of that is unknown at the time the IPE is being prepared, the comparable benefit field can be left blank. This will print out on the IPE as Comparable Benefit unknown.
  3. When ACCES-VR has provided services without obtaining comparable benefits the record of service should document this as follows:
    1. Medical risk:
      The record of services must identify the specific medical condition and how it poses a risk to the participant. This must be based on documented medical information.
    2. Loss of job placement:
      The record of services must identify the job and employer, and briefly justify how a delay in pursuing comparable benefits would have resulted in the loss of a job placement.
    3. Benefits not available to implement the IPE
      The record of services must identify the comparable benefit, the reason it is not available, and describe why a delay in the provision of services impacts on attaining the objectives in the IPE.