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d. 1. The designated State unit's plans, policies, and procedures for coordination with education officials to facilitate the transition of students with disabilities from school to the receipt of VR services, including pre-employment transition services, as well as procedures for the timely development and approval of individualized plans for employment for the students

Current Narrative:

The following section outlines how IDVR meets the requirements of 34 CFR 361.22: Coordination with education officials.

(a) Plans, policies, and procedures.

(1) The vocational rehabilitation services portion of the Unified or Combined State Plan must contain plans, policies, and procedures for coordination between the designated State agency and education officials responsible for the public education of students with disabilities that are designed to facilitate the transition of students with disabilities from the receipt of educational services, including pre-employment transition services, in school to the receipt of vocational rehabilitation services under the responsibility of the designated State agency.

(2) These plans, policies, and procedures in paragraph (a)(1) of this section must provide for the development and approval of an individualized plan for employment in accordance with § 361.45 as early as possible during the transition planning process and not later than the time a student with a disability determined to be eligible for vocational rehabilitation services leaves the school setting or, if the designated State unit is operating under an order of selection, before each eligible student with a disability able to be served under the order leaves the school setting.

The Division has developed and maintains policies and procedures for IDVR staff in Section 9 of the Field Services Policy Manual: Pre-Employment Transition.  This section contains field guidance under the following categories:

  • IDVR Policy: Pre-Employment Transition and Transition Services for Students and Youth outlines Division policy for internal staff and includes sections on Pre-ETS, Service Provision and Collaboration with Schools, Potentially Eligible Students, Pre-ETS services for students, transition services, youth with a disability, student with a disability, IPE development, Pre-ETS services exemption from financial participation, auxiliary aids or services, and guidance for Pre-ETS delivery under Order of Selection (note: IDVR is not currently under OOS and does not anticipate entering OOS according to current projections).  IDVR Policy defines Student with a Disability including age and education requirements within this policy.  The earliest a student can engage in Pre-ETS is 14 as agreed to by IDVR and ICBVI. This age was determined through collaboration with our blind agency ICBVI and the state department of education during development of our Interagency Agreement. We determined the start age of 14 because of statewide initiative with CTE that is focuses on middle school. The age is documented in our Interagency Agreement. It has been communicated to IDVR staff through the Pre-ETS Guidance Document.
  • IDVR Procedures: Pre-Employment Transition Services: This document is a guide for IDVR staff outlining Pre-ETS Procedures. This guide does outline some contract processes and guides to help IDVR staff understand the differences in how contracts are framed, but all contract requirements and actual contracts are conducted as a separate formal process following all required policies and rules outlined by the Idaho Division of Purchasing (as outlined in individual contracts and designed to meet the requirements of this section). IDVR staff can only approve and authorize services within the context of their position, approval authority, and as outlined in policies and procedures.  Processes include: LEA paid work process (with procedures for LEA and IDVR staff), traditional IPE case Pre-ETS processes, pre-case type processes, LEA summer programs, Occupational Preparation Advocacy Lab, CTE Exploration Program, IESDB (LEA) Summer Work Camp and Paid Work Experience, Idaho Parents Unlimited (IPUL) Work of Art, Institutes of Higher Education (IHE) Programs (Summer and School Year sections), Summer Bootcamp, Summer Self-Advocacy classes, Tools for Life,  Summer Work Experience, Employer Reimbursed Work Experience (100-hour), 40-Hour individual CRP employer Work Readiness Training and Work Experience, Job Shadows (VR provided and CRP based), Vendor travel for remote and underserved areas, Conover online, The Idaho Transition Institute, and a Pre-Case Checklist guide.


IDVR maintains multiple documents for the purposes of Pre-ETS planning.  These include the IDVR Pre-ETS Strategic Plan, the Statewide Transition Plan (STP), and other relevant transition plans (as needed).

(b) Formal interagency agreement.

The SDE, IDVR, and ICBVI have developed a comprehensive formal interagency agreement which meets the requirements of 34 CFR 361.22(b)(1-6) by addressing eligibility criteria, collaborative service provision, consultation and technical assistance, including the programmatic and fiscal responsibilities for each agency, as well as procedures for outreach, application (when required) and early engagement.  The latest amended agreement is in effect as of January 2022.

Additionally, the Agreement details that the IPE must be developed, agreed to and signed by the student, or the student's representative, and the VR counselor, as early as possible in the transition process, within 90 days from eligibility and no later than the time the student leaves the school setting, whichever is earlier.

This agreement provides the assurances required for coordination with 34 CFR 397 (Limitations on the use of subminimum wage) for proper notification and documentation requirements when a student becomes known to be seeking less than minimum wage employment. Additionally, the agreement notes SDE and LEA responsibilities to:

  • Per 34 CFR 397.31 neither the Idaho State Department of Education nor a local education agency will enter into an arrangement with an entity holding a special wage certificate under section 14(c) of the Fair Labor Standards Act for the purpose of operating a program under which a youth with a disability is engaged in work at subminimum wage.

Specific criteria are used to determine which agency (IDVR, ICBVI or LEA) has the primary responsibility for providing and paying for transition related services for students with disabilities. These criteria are based on several factors, including the purpose of the service, which entity customarily provides the service, and program eligibility (per 34 CFR 361.22(c)). 

IDVR Pre-Employment Transition Highlights. The Division has developed Pre-ETS implementation strategies to provide services at the following levels, including all required pre-employment transition services (job exploration counseling, work-based learning experiences, counseling on opportunities for enrollment in postsecondary education, workplace readiness training to develop social skills and independent living, and instruction in self-advocacy). The Division has continued to modify and improve these strategies, including the coordinated and authorized services, as service delivery and partnerships evolve. For example, the Division has developed numerous Memorandum of Agreements (MOAs) with various Local Education Agencies (LEAs). These include contracting with educators to provide a Self-Advocacy curriculum for students previously developed through a partnership between the Idaho State Department of Education, IDVR, an Idaho LEA, and the National Technical Assistance Center on Transition (NTACT). The Division has also developed MOAs to provide students with an opportunity to participate in a paid work experience while earning summer school credit.

The Division has also improved coordinated activities by having our VR Counselors work collaboratively with local school personnel to develop effective referral and outreach strategies to maximize opportunities for students with disabilities to participate in Pre-ETS activities. These strategies also include opportunities for students who are receiving accommodations under Section 504 of the Rehabilitation Act. VR Counselors are attending numerous IEP meetings and are working with districts to develop a better process for inviting VR counselors to IEP meetings.  In addition, VR Counselors are working with districts to coordinate pre-employment transition services. VR Counselors are working with LEAs to provide career fairs and career mentoring.

IDVR also now has three area transition counselors (ATCs) whose focus is to increase the number of students receiving pre-employment transition services and to increase the number and types of services that are available to students. They use our Power BI data to evaluate where we are low in referrals or have limited student involvement in Pre-ETS. They specifically target service provision in these areas; these are largely rural areas. Additionally, they are attending an increased number of IEP meetings to assist with coordinated services. One counselor covers northern Idaho, one cover southeast and south-central Idaho, and one covers southwest Idaho.

The ATCs have also worked hard to develop strong working relationships with counselors and within the schools. The ATCs have provided presentations to many school districts (both virtual and in-person) where they discuss various services that are available to the students and to discuss the referral process. They have also provided informational group meetings with parents and students. The ATCs have also participated in many Pre-ETS planning sessions with schools that were identified by IDVR as underserved/underrepresented for their size.  These planning sessions have been productive and have increased student engagement from those schools.  The ATCs have meetings with special education directors to identify their perception of student needs to best assist with the transition out of high school.  Additionally, these ATCs hold discussions to better gauge perceptions of the VR/school alliance and how we can further strengthen this relationship.

The ATCs have also worked with the school-to-work counselors closely.  ATCs meet with SWT counselors on a regular basis to brainstorm ideas, address emerging issues, and discuss Pre-ETS in general.  They have worked with several staff to set up WBLE for rural LEAs.  Additionally, ATCs attended several events with SWT counselors for deeper engagement with school districts with projects such as Reality Town, school presentations, a tour of multiple CTE programs, career fairs, or observing programs at the LEA.  They have also actively engaged with LEAs to help start 18-21 programs with plans to expand this initiative to other schools.

Finally, the ATCs have worked with new IDVR staff to introduce them to the world of Pre-ETS.  This early staff training is important as Pre-ETS is a major part of the VR process.  The ATCs have also been the main point of contact for many schools when a region experienced significant staff turnover.  This has been an important task as we work to maintain positive relationships with school districts and not lose the progress, we have made this year.

The Division also works with the State Department of Education, the Idaho Commission for Blind and Visually Impaired, LEAs, Institutes of Higher Education (IHEs), and the Council for Developmental Disabilities to put on a Transition Institute for LEAs and VR staff. The Institute is modeled after NTACT Taxonomy for Transition Programming. The Taxonomy for Transition Programming provides solid practices identified from effective programs and evidence-based predictors of post-school success for implementing Pre-ETS and transition focused education. This Institute allows collaborative planning between LEAs and VR.  Teams, at the regional level, discuss what transition/pre-employment transition services are available to students and what services are needed by students based on each district. Teams then create plans to help increase the necessary services for students with disabilities.

The Division has strong relationships with education agencies throughout the state, including formal interagency agreements with several Local Education Agencies (LEAs), a comprehensive formal interagency agreement which addresses collaborative service provision with the State Department of Education (SDE), and the Idaho Commission for Blind and Visually Impaired (ICBVI).

The Division and the SDE have developed a comprehensive formal interagency agreement which addresses collaborative service provision. This agreement specifies the programmatic and fiscal responsibilities for each agency and identifies the minimum age for service delivery to students with disabilities.  The minimum age is 14 for service delivery to students with disabilities. 

The pre-employment transition services will be provided to students with disabilities who are potentially eligible or eligible for VR services.  This agreement was formalized and signed in November 2020.  The agreement is reviewed annually for relevance and will be amended by mutual consent as needed.

Lastly, the Division has partnered with the SDE to implement a Statewide Secondary Transition Plan which correlates to the Division’s Pre-Employment Transition Plan. The goal on the statewide plan is to develop systems for effective collaboration between students, families, secondary and post-secondary educators, rehabilitation counselors, Career and Technical Education (CTE), and service providers to provide quality transition activities and pre-employment transition services to students across Idaho. The Statewide Transition Plan is further detailed in section 2B.