Vocational Rehabilitation Program (Combined or General)

There are three key critical factors to consider in determining whether VR must continue to operate under an order of selection: staffing capacity, fiscal resources, and the amount of time necessary to serve eligible individuals assigned to a closed disability priority category who are in deferred services status. As of December 2021, 2663 eligible individuals are assigned to a closed disability priority category and have been deferred for services. Indiana anticipates that approximately 700 newly eligible individuals will be assigned to a closed disability service priority category annually.

BRS has outlined five sequential steps to work toward serving all eligible individuals, ensuring federal requirements to serve individuals in order of disability priority and application data are met:

Step 1 – serving VR eligible individuals assigned to disability priority category 1, or those with the most significant disabilities. Priority category 1 is ‘open.’ Priority category 2 (individuals with significant disabilities), and priority category 3 (all other eligible/non-significant disability) are ‘closed,’ meaning that VR eligible individuals assigned to categories 2 and 3 are deferred for services. Approximately 87% of eligible individuals are assigned to Priority Category 1 are prioritized to receive services, with 13% experiencing a waitlist period.

Step 2 - As VR identifies that resources are adequate, individuals in priority category 2 will be released from deferred services status in phases. VR has released approximately 1000 individuals assigned to Priority category 2 from deferred status as of the end of 2021. Estimated staffing and fiscal resource needs outlined further below are focused on building capacity to continue to proceed with step two.

Step 3 - After step 2 is complete, VR would then assess whether staffing and fiscal capacity are adequate to progress to step 3, which is opening priority category 3. Once a category is open, there is no waiting time for services for newly eligible individuals assigned to that open category. The actions outlined for steps 2 and 3 would then be repeated for steps 4 and 5, dependent on sufficiency of resources, for priority category 3.  

Each of these three key factors – staffing capacity, fiscal resources, and length of time to complete each sequential step outlined above - will be addressed below, including specific challenges with each factor as well as strategies to mitigate challenges.

Staffing capacity: Since implementing an order of selection in August 2017, VR has closely reviewed the percent of eligible individuals determined to meet criteria for priority category 1 (individuals with a most significant disability), an open service category. The percentage of eligible individuals assigned to priority category 1 is currently 87%. Indiana recognizes that it is not uncommon to see an increase in the percentage of eligible individuals determined to meet criteria for open service categories once a VR state agency implements an order of selection, and did anticipate some increase, however the increase was larger than projected. Prior to order of selection, approximately 42% of eligible individuals met criteria for priority category one, and the increase to 87% is significant.

On average, 20-25% of VR Counselor positions were either vacant or filled with new staff in trainee status during FFY2019. This improved to less than 10% of vacant or new staff in positions in FFY20-21 due to implementation of numerous initiatives including salary adjustments, creation of VR Counselor Specializations, staff recognition opportunities, streamlined communication, and improved training. The improvements in VR staff retention have enabled VR to progress to step 2 and approximately 1,000 individuals have been released from the order of selection waitlist from priority category 2. As of the end of 2021, 1553 individuals remain on the priority category 2 wait list.

While VR staff capacity has improved, staff retention and recruitment challenges have significantly increased within our VR provider network over the past two years. Many providers have waiting lists for services because they are having great difficulty recruiting and retaining qualified staff, and this has become particularly challenging with the onset of the COVID-19 pandemic. VR is working toward implementing strategies to mitigate these challenges, but at this time, provider staff capacity remains a factor that must be considered in the assessment of Indiana VR’s ability to continue to release individuals from the order of selection waitlist at the current pace.

Demands on VR Counselors were significantly increased with requirements under WIOA, such as increased data collection and required post-exit follow up on VR participants. Indiana VR has also revised expectations of VR Counselors regarding engagement in the employment services process, to ensure a team approach to job placement and supported employment services. With these modified requirements and expectations, ideal average caseload sizes must be smaller. This is another critical factor to consider when assessing capacity to release individuals from the wait list. Great strides have been noted in achieving manageable caseload sizes and it will be critical to maintain these manageable levels going forward. Obtaining manageable caseload sizes has been key to improving staff retention.

The current average caseload size has been around 75-80 participants per counselor position over the last couple of year, which BRS considers to fall within an ideal range. The caseload size ratio is currently higher based on some atypical turnover during the latter half of 2021 and the higher than typical number of staff in trainee status. Overall, much improvement has been realized through efforts to improve internal VR staff capacity, however, the increasingly competitive job market is having some negative impact on retention and recruitment of VR staff. Furthermore, staff recruitment and retention challenges among the VR provider network have exacerbated.

Fiscal Resources: A primary fiscal challenge is the federal requirement to earmark 15% of federal funds for pre-employment transition services (Pre-ETS). This shift in funds reduced the amount of funding available for VR client services for eligible VR participants. While BRS has taken steps to mitigate this challenge, the requirement to shift funds nevertheless presents significant challenge. VR’s earmark requirement is estimated at approximately $9.2M for FFY22, which reduces the available budget for VR client services to an amount insufficient to provide the full range of VR services to all eligible individuals.

Additional staff positions will be necessary to continue to build staff capacity to support the provision of services to all eligible individuals as Indiana works to end the order of selection over the next several years, however this also has a fiscal impact. Any additional staff positions will result in added and ongoing expense. The need for expanded or altered office space to accommodate any added staffing also has a budget impact. All of these factors must be considered in determining whether fiscal resources are adequate to provide the full range of VR services to all eligible individuals. Indiana VR continues to lack sufficient fiscal resources to serve all eligible individuals. Of the 2663 total number of eligible individuals deferred for services as of the end of 2021, 1553 were assigned to priority category 2. VR has sufficient fiscal resources to serve a portion of these individuals over the next two federal fiscal years as previously outlined, however does not have sufficient fiscal resources nor staff capacity to serve all individuals waiting for services in FFY22 or FFY23. Staff and fiscal capacity is insufficient to open all disability priority services categories at this time.

Length of time to serve eligible individuals assigned to a closed disability priority category: While fiscal and staffing resources are two critical factors to evaluate in order to determine capacity to provide the full range of VR services to all eligible individuals, a third equally critical factor must be considered. The third factor is the amount of time necessary to serve the eligible individuals in deferred services status. As of the end of 2021, 2,663 VR eligible individuals were in deferred services status (i.e., assigned to closed disability priority categories). While two priority categories remain closed, Indiana VR anticipates that approximately 700 newly eligible individuals will be assigned to a closed disability service priority category annually. Therefore, the total number of eligible individuals deferred for VR services will continue to grow as VR works to release individuals in delayed status in over several phases.

There are five sequential steps that must be followed in serving individuals in deferred status, in order of priority and application date as federally required. Those five steps are outlined in more detail below to better articulate how the ‘length of time’ factor must be considered in determining the ability to move out of an order selection.

Step One: Step one as indicated in the graphic above is the current status, with all eligible individuals assigned to priority category 1 receiving VR services with no waiting period. Approximately 80% of eligible individuals are assigned to priority category 1.

Step Two: When VR determines that sufficient resources are available, step two is to begin serving eligible individuals deferred for services who are assigned to priority category 2. These individuals must be served in order of application date and would be released from deferred status in phases. It is important to understand that disability priority category 2 remains ‘closed’ until all eligible individuals deferred for services in service priority category 2 are served. This means that during step two, newly eligible individuals assigned to priority category 2 would continue to experience a waiting period before services could begin.

Step Three: After all eligible individuals in priority category 2 who have been deferred for services have the opportunity to develop an IPE to initiative services, VR will determine whether fiscal and staffing resources are adequate to progress to step three, which is opening priority category 2. Once a priority category is open, there is no waiting period for services for individuals assigned to that category.

Step Four: The process outlined in Step two is repeated for individuals in deferred status in priority category 3.

Step Five: The process outlined in Step three is repeated for individuals in deferred status in priority category 3. Once all disability service priority categories are open, VR moves out of order of selection.

Given the sequential steps required to move out of an order of selection, VR has focused its assessment of capacity and resource needs on movement to step two as outlined in the process above. VR has been releasing individuals in priority category 2 from deferred status in phases. VR has reviewed the service area location of individuals deferred in priority category 2 to assess staff capacity at each individual field office. This has been a useful exercise in determining the number of individuals to be released at a given time. As of the end of 2021, VR has completed four separate releases with an approximate total of 1,000 individuals released from delayed status since January 2020.

VR’s available and projected resources are not adequate to ensure the provision of the full range of vocational rehabilitation services, as appropriate, to all eligible individuals in FFY22 and FFY23. In consideration of the three factors as outlined above, staff capacity, fiscal resources, and time needed to serve those in deferred services status, BRS must continue to operate under an order of selection. BRS plans to continue releasing eligible individuals deferred for services in priority category 2 throughout FY22 and FY23, however anticipates that two priority categories will remain closed during this period.