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d. 2. C. Roles and responsibilities, including financial responsibilities, of each agency, including provisions for determining State lead agencies and qualified personnel responsible for transition services;

Current Narrative:

IDVR has continued to participate in agreements with many LEAs across Idaho, initiated prior to WIOA, however these agreements do not afford unique services to students in these districts.  In other words, Pre-ETS and transition services offered under these agreements do not increase services or expand the scope of services over any other political subdivision of the state.  All Pre-ETS and transition services are offered statewide to all LEAs regardless of agreement status.  IDVR has staff assigned to all public high schools across the state.

Idaho State Department of Education (SDE) - Secondary Transition:

Idaho Division of Vocational Rehabilitation (IDVR), Idaho Commission for Blind and Visually Impaired (ICBVI), and the State Department of Education (SDE) agreement ensures a coordinated, comprehensive system focusing on students with disabilities as they transition from secondary school to post-school activities, promoting post-secondary education, vocational training, competitive integrated employment (including supported employment), continuing and adult education, adult services, independent living, and community participation emphasizing a team approach to facilitate the transition of students with disabilities from public education into employment.

This agreement addresses the following:

  • Pre-Employment Transition Services will be provided to students with disabilities who are potentially eligible or eligible for VR services beginning at the age of 14.
  • Roles and responsibilities of each agency, including which agency is state lead
  • Financial responsibilities of each agency, including the purchase of Assistive Technology
  • Procedures for outreach, consultation, training, and technical assistance
  • Transition planning
  • Referral process for students with disabilities to the appropriate VR program
  • Data release and data sharing
  • Dispute resolution
  • Prohibition on entering into an arrangement with an entity holding a 14(c) special wage certificate for the purpose of operating a program where people with disabilities are engaged in work at subminimum wage.
  • Coordination and documentation requirements under section 511

IDVR has created a Youth Subminimum Wage Document Requirements Checklist which includes the documentation requirements and responsibilities under Section 511.  Various requirements are detailed in the top-level checklist for youth, including the requirement for a transition or Pre-ETS service to be completed prior to youth verification of Career Counseling and Information and Referral (CCI&R) under Section 511.  The Transition Services Documentation and Checklist details LEA requirements for documenting provision of a transition service.  Finally, the Youth Career Counseling Verification Requirements section outlines areas and responsibilities of IDVR in ensuring regulations are met ahead of providing verification of receipt of CCI&R. 

Section 511 Subminimum Youth Checklist

The following steps must be completed before IDVR can provide verification of Career Counseling and Information and Referral to Youth Seeking Subminimum Wage Employment

  1. The provision and documentation of transition services or pre-employment transition services (a. or b. must be completed) 
    1. Transition Services Documentation Checklist Completed
    2. Pre-employment Transition Services Documentation Checklist Completed
  2. Application for VR services AND one of the following (a. b. or c. must be completed)
    1. Ineligibility Determination Checklist Completed
    2. Closure after an Approved IPE Checklist Completed
    3. Informed Choice Not to Pursue Competitive Integrated Employment Form Completed
  3. The provision of Career Counseling, and Information and Referral Services (ALL must be completed)     
    1. Youth Career Counseling Verification Elements Signed by Counselor
    2. Information and Referral Packet Provided to Youth
    3.  Career Counseling, Information and Referral Youth Verification Form for Stated Subminimum Employment Goal Completed
  4. Once all of the preceding steps have been satisfied, verification of CC/I&R can be provided to the youth and they would be able to legally work for less than minimum wage. The 511 Subminimum Youth Checklist only has to be completed once. After the youth completes this process, they would engage in group sessions at the 14c to meet ongoing requirements for CC/I&R for youth.

Section 511 Transition Services Documentation Checklist and Cover Sheet

34 CFR § 397.30 outlines the responsibilities of local educational agencies to youth with disabilities who are known to be seeking subminimum wage employment. All elements of this form must be completed in order for the checklist to be considered valid evidence of the completion of transition services for the purposes of satisfying Section 511 requirements of the Workforce Innovation and Opportunity Act.

  1. (To be completed by the Local Education Agency): The documentation of completion of appropriate transition services for a youth with a disability under IDEA           
    1. This can be transmitted in the form of an Individualized Education Plan, but must contain at a minimum (please verify the following are contained in this release):                     
      1. Youth’s name
      2. Description of the service or activity completed
      3. Name of the provider of the required service or activity
      4. Date required service or activity completed
      5. Signature of educational personnel documenting completion of the required service or activity
      6. Date of signature documenting completion of the required service or activity
      7. Date and method (e.g., hand-delivered, faxed, mailed, emailed, etc.) by which document was transmitted to IDVR
      8. A cover sheet that itemizes the documentation that has been provided to the VR program regarding that youth (completion of the elements above satisfies this requirement)
      9. Verification that the educational agency will keep a copy of all documents sent to the VR program
      10. Signature of the individual transmitting this documentation
  2. (To be completed by Vocational Rehabilitation):          
    1. Verification that VR has filed a copy of this information
    2. Verification that this information has been provided to the youth

Youth Career Counseling Verification Elements

Prior to initial verification of CCI&R for youth known to be seeking subminimum wage employment, IDVR must ensure counselors providing the service address the following elements of the VR process including a discussion of competitive integrated employment and services available at VR to assist the individual in making an informed choice whether or not to continue pursuit of employment with a 14(c) certificate holder.

  1. Self-advocacy, self-determination, and high expectations         
    1. Identify the individual’s desires for employment including type, pay, hours, benefits, etc.
    2. Ensure informed choice
  2. Review of any assessment information available          
    1. Primary employment factors                 
      1. Strengths
      2. Interests
      3. Abilities
      4. Capabilities
      5. Resources
      6. Priorities
      7. Concerns
      8. Informed Choice
    2. Person-centered planning
    3. Marketable skills
    4. Soft skills (current and where development is needed)
  3. Use of labor market information           
    1. In-demand occupations
    2. Job exploration             
      1. Education and experiential requirements
      2. Pay
      3. Hours
      4. Functional capacity requirements
      5. Career pathways
    3. Electronic resources and navigation fundamentals
  4. SSA Benefits Planning

When engaging in career counseling with individuals with disabilities, rehabilitation professionals should ensure that they are aware of cultural differences and that they discuss the available options such as supported or customized employment. A discussion of the need for assistive technology or reasonable accommodation on the job is important to maximize the potential for success. It is helpful to assess the individual’s support system and to provide information on available resources for the individual.

A completed signature sheet (signed by the customer and VR counselor) affirming that the elements of Career Counseling have been discussed with the customer in the course of the provision of Vocational Rehabilitation Counseling and Guidance.

The current agreement establishes the following roles and responsibilities for the involved parties:

The Idaho State Department of Education (SDE) agrees to:

  • Assume the role of lead agency in facilitating interagency planning with LEAs and implementing educational programs and transition services for students with disabilities from high school to post-high school services.
  • Support LEAs in their efforts to write IEPs using an outcome-oriented focus and to coordinate transition activities for each IEP eligible student, beginning no later than the IEP created before the student turns age 16 years old (earlier if appropriate), and to address future student needs in the areas of post-secondary education, vocational training, employment, and adult living and communication participation, including assistive technology.
  • Support LEAs to collaborate with the student and the family to plan and provide educational services to meet individualized educational objectives, which are documented on an IEP.
  • Support LEAs to work in partnership with the student, the student's family, and other community resources to coordinate services within the community.
  • Support LEAs to provide ongoing information to the student and the family about the student's educational development.
  • Invite IDVR and/or ICBVI to provide information regarding their services, including their role as an IEP team member to school district personnel, students, and their families.
  • Invite IDVR and/or ICBVI counselors, with prior consent from adult students or parents or legal guardians, as appropriate, to participate as members of IEP teams for students who have been referred to IDVR and/or ICBVI for rehabilitation services, or earlier if appropriate.
  • Work with IDVR and ICBVI Vocational Rehabilitation (VR) counselors to identify a process for such counselors to provide input and participate in the development of a student’s IEP, including pre-employment transition services, when appropriate.
  • Identify appropriate school personnel who, with prior consent from adult students or parents or legal guardians, as appropriate, will initiate the referral process of students receiving special education services, and students who have a 504 Plan (Rehabilitation Act of 1973), or students with disabilities (e.g., physical, medical, or visual, etc.) who are not eligible for special education services, to IDVR and/or ICBVI for pre-employment transition services and/or vocational rehabilitation services.

Idaho Division of Vocational Rehabilitation (IDVR) and Idaho Commission for the Blind and Visually Impaired (ICBVI) agree to:

  • Agree to establish the age of 14 to begin working with students with disabilities.
  • Encourage staff to work closely with LEAs to ensure coordination between education services, pre-employment transition services, and vocational rehabilitation services.
  • IDVR and ICBVI counselors will provide training and information to school district personnel, students and families on pre-employment transition and vocational rehabilitation services, including their role as IEP team members.
  • IDVR and ICBVI counselors are available to consult with educators concerning pre-employment transition and vocational rehabilitation services for students to assist them toward employment.
  • IDVR and ICBVI counselors will collaborate with the LEAs in their service area to identify a process for the counselors to provide input and participate in the development of the transition services included in IEPs.
  • IDVR and/or ICBVI counselors may attend IEP team meetings for each referred student upon timely invitation by school personnel and the student and/or student’s parent or legal guardian. VR counselors may attend either in person or via video/telephone. The IDVR and/or ICBVI counselors will provide written recommendations, if requested, for use in developing IEPs when unable to attend.
  • IDVR and ICBVI counselors will consult with educators concerning referral of students to IDVR and/or ICBVI for rehabilitation services, including pre-employment transition services. Students with blindness or visual impairments should be referred to ICBVI. Students with multiple disabilities may have dual cases with both IDVR and ICBVI to provide rehabilitation services.
  • IDVR and ICBVI counselors will accept referrals for pre-employment transition or vocational rehabilitation services, when appropriate, and will work collaboratively with input from the student’s IEP team, for service provision and/or to develop an IPE. The vocational rehabilitation counselor, student, student’s parent or legal guardian, and members of the student’s IEP team will collaborate to identify required vocational rehabilitation services that will move the student towards their employment goal.
  • All Vocational Rehabilitation State Plan requirements, including Order of Selection, will apply to all services provision under this cooperative agreement.