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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:

Indiana VR and key partners continue to build a collaborative infrastructure for the purpose of streamlined transition of students with disabilities from school to the receipt of VR services, including pre-employment transition services (Pre-ETS) which are available to students with disabilities, age 14 through the school year in which they turn 22, and are eligible or potentially eligible for VR services.  Ongoing Indiana initiatives and WIOA requirements are aligned for VR to coordinate with Education officials and other key partners (e.g., Department of Workforce Development) to identify the best methods for providing successful transition services to students. 

A Memorandum of Understanding between BRS and DOE outlines each respective agency responsibilities, including requirements pertaining to subminimum wage employment and coordination between VR and schools in ensuring that youth receive career counseling and information and referral services prior to entering subminimum wage employment. Additionally documentation requirements are outlined in the MOU including the process for providing documentation of required actions to be completed prior to entry into subminimum wage employment and the type of documentation needed.  The MOU also address the prohibition on schools entering into agreements with 14c certification holders. Additionally, BRS has developed a template to be used to capture all required elements. Specific excerpts from the MOU are included below:

Partner Agencies will coordinate efforts to comply with Section 511 of the Rehabilitation Act, limitations on the payment of subminimum wages. This will include development of procedures and processes to meet documentation requirements regarding required activities in which youth must participate prior to participating in subminimum wage employment. Partner Agencies will also educate LEAs, local VR staff, parents, students, and other stakeholders about applicable requirements outlined in Section 511 of the Rehabilitation Act, and ensure that youth have access to career counseling, information and referral, and other services and resources to assist them in pursuing competitive, integrated employment.

Under the Section 511 of Rehabilitation Act, 14(c) businesses referred to as “employers” are prohibited from employing any individual with a disability who is 24 years of age or younger at subminimum wage, unless the individual has received documentation from DDRS upon completion of all the following activities:

1. Received Pre-ETS through DDRS, or transition services under the Individuals with Disabilities Education Act (IDEA); and

2. Applied for VR Services and was determined a. Ineligible for VR Services, or b. Eligible for VR Services, had an approved Individualized Plan for Employment, and was unable to achieve an employment outcome in competitive, integrated employment after a reasonable period of time, and his/her case was closed; and

3. Received career counseling and information and referral services to federal and state programs to help the individual discover, experience, and attain competitive integrated employment, and the counseling and information was not for employment at sub-minimum wage.

These requirements should be shared by DOE with LEAs, parents, guardians, teachers and students. DDRS will maintain the documentation and provide a copy to the individual within the timelines identified as specified under 34 CFR part 397. Any of the services identified above that the LEA provides must be documented by the LEA and provided to the student and DDRS.

DDRS, in consultation with DOE must develop or use an existing process to document the completion of this process as well as the transmittal of documentation from DOE to DDRS, consistent with the confidentiality requirements of the Family Education Rights and Privacy Act (20 USC 11232g(b) and 34 CFR 99.30 and 99.31) and IDEA (20 USC 1417(c) and 34 CFR 300.622) pursuant to Section 511(d) of the Act and §397.10. This documentation must contain, at a minimum (§397.10(a)(1)):

● The youth’s name;

● The determination made, including a summary of the reason for the determination or a description of the activity or service completed;

● The name of the individual making the determination or the provider of the service/activity;

● The date the determination was made or the required service or activity completed;

● Applicable signatures and dates by DDRS or DOE making the determination or completion of the required services or activity;

● Signature of the DDRS personnel transmitting documentation to the youth with a disability;

● The date and method by which the document was transmitted to the youth (e.g., hand delivered, faxed, mailed, emailed, etc.); and

● DDRS and DOE must retain copies of the documentation in a manner consistent with the requirements of 2 CFR 200.333.

If a youth with a disability or, as applicable, the youth’s parent or guardian, refuses, through informed choice, to participate in the activities required by Section 511 or the implementing regulations in 34 CFR Part 397, documentation must, at a minimum, include the following:

● The youth’s name;

● A description of the refusal and the reason for the refusal;

● The date and signature of the youth or, as applicable, the youth’ parent or guardian;

● Applicable signatures and dates by DDRS or DOE documenting refusal;

● The date and method by which the document was transmitted to the youth (e.g., hand delivered, faxed, mailed, emailed, etc.);

−This information must be provided by DDRS to the youth within 10 calendar days of the youth’ refusal to participate.

−Refusal to participate in transition services requires DOE to provide DDRS with documentation of the refusal within 5 calendar days.

−DDRS and DOE must retain copies of the documentation in a manner consistent with the requirements of 2 CFR 200.333.

Neither DOE nor the LEA 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 a subminimum wage.

[end of MOU excerpt]

Serving transition-aged students continues to be a priority for VR, even more so with the advent of WIOA and Pre-ETS.  Through the efforts of VR’s dedicated transition staff, the Director of Youth Services and the Coordinator of Youth Services, VR has expanded Pre-ETS to all 92 Indiana counties and to approximately 400 schools statewide, with education to key stakeholders being a major part of this expansion. This includes VR staff and contractors providing Pre-ETS across the state, as well as outreach and education to students, parents, educators, and others.  This education and outreach serves not only to educate about Pre-ETS requirements and availability, but also to quell misconceptions about services.  This training has included face-to-face meetings with Pre-ETS contractors for the purpose of sharing resources, expectations, and accomplishments. Training with Pre-ETS contractors has also included webinars to VR staff, parents, and educators, presentations to local school systems, and providing ongoing updates to the statewide VR Transition Advisory Council.  The focus of much of this outreach has been to aid in understanding of how Pre-ETS is being made available to students with disabilities across the state.  VR assisted in training Pre-ETS Career Coaches throughout the state in the utilization of the LifeCourse for Pre-ETS students, collaborated with DOE on training Pre-ETS contractors between the intersection of DOE’s new graduation pathways and Pre-ETS, and initiated pilot projects with several Pre-ETS contractors and local education agencies to improve communication and information sharing on Pre-ETS activities, and portfolio and IEP requirements.

To assist with Pre-ETS continued expansion of education and outreach to key stakeholders, this year, VR instituted a new role, the VR Youth Counselor and has hired 8 of the 10 available positions. Youth counselors work in their respective regions throughout the state assisting with transition and Pre-ETS activities. They have begun working on needs assessments with VR area offices, school systems and Pre-ETS contractors and have already introduced many positive changes. They have helped to strengthen the referral process and communication in general with VR and many school systems, assisted providers in accessing schools where Pre-ETS was not widely available, and provided numerous trainings and technical assistance to Pre-ETS and transition stakeholders.

VR, in collaboration with DOE, established a Statewide Transition Advisory Council to identify and address the barriers that continue to impact students with disabilities, and develop and implement strategies and services to make the transition successful for students and youth with disabilities. The Transition Advisory Council serves as the VR/DOE MOU Oversight group and has provided input and recommendations into the 5 key oversight areas in the newly updated MOU with DOE. These 5 areas are:

  1. Reviewing, addressing and facilitating resolution of concerns relating to transition and Pre-ETS for students with disabilities.
  2. Supporting joint training for Partner Agency staff to promote mutual understanding of each Partner Agency's systems.
  3. Providing professional development and technical assistance to LEAs and VR Area Offices that enhance collaboration and involvement with community based organizations, employers, employer groups, and other agencies.
  4. Developing and implementing processes for sharing appropriate individual or aggregate data and information regarding students with disabilities, who are being served or may potentially be served by a Partner Agency.
  5. Identifying ways to provide timely information to students with disabilities and their families regarding specific work incentives and the positive impact of work on government benefits.

The Statewide Transition Advisory Council includes representation from a wide range of key partners and stakeholders, including the following: VR, DOE, local educational agencies’ school personnel and administrators, Indiana Council of Administrators of Special Education (ICASE), the Bureau of Developmental Disability Services (BDDS), the Department of Workforce Development (DWD), Department of Corrections, Center for Deaf & Hard of Hearing Education (CDHHE), Community Mental Health Centers, Indiana Association of People Supporting Employment First (INAPSE), Indiana Association of Rehabilitation Facilities (INARF), Indiana Institute of Disability and Community – Center on Community Living and Careers (IIDC - CCLC),  parent representation, the Arc of Indiana, INSOURCE, and other family advocacy groups.

VR works closely with IIDC-CCLC at Indiana University Center of Excellence on several transition-related priorities.  IIDC-CCLC promotes partnerships among Indiana schools and various state agencies and other support organizations.  Theirs focus is on career development, secondary education, and transition to adult life.  As part of the need to establish an infrastructure and ensure sustainability of transition services, including Pre-ETS, VR works with the existing Transition Cadres in Indiana.  Established in 2011 and dedicated to improving secondary transition outcomes for students, a network of Transition Cadres Leaders throughout Indiana (funded by DOE) is working collaborative, both regionally and statewide.  The efforts are focused on implementing promising practices and creating innovative strategies, tools, and resources for teachers and other transition professionals.  VR has provided training on VR services and Pre-ETS to the Cadres, and VR Youth Counselors attend the regularly scheduled cadre meetings to continue the joint collaboration. For more information: http://www.iidc.indiana.edu/pages/cadre-leaders.

In coordination with IIDC-CCLC, VR developed written informational materials for educators and students. The fact sheets provide resources for students, teachers, and families about VR at students’ Transition IEP meetings.  IIDC-CCLC, along with partners from the Governor’s Workforce Cabinet and Office of Career and Technical Education, DOE, IN*Source, and YTac, a federal technical assistance center, created the Career and Technical Education (CTE) workgroup with the goal of increasing enrollment of and positive outcomes for students with disabilities in CTE. The workgroup is in the process of interviewing select CTE sites to determine their protocol for student selection, resources for assisting students with disabilities, and overall success rate. This information will be used to identify pilot sites throughout the state with the goal of providing training, technical assistance and other support to increase the number of students with disabilities enrolled and successfully completing CTE courses.

VR has counselors assigned to each school for outreach and education to teachers, students, and parents.  These VR counselors collaborate with school staff to enable a seamless transition to life after high school.  The goal for each student is for a VR application to be completed, and, for eligible participants who are being served, to have an Individualized Plan for Employment (IPE) in place, before exiting high school. While this process works well in many cases, our youth counselors are in the process of identifying any areas of need in order to increase communication, improve the referral process and ensure students with disabilities are identified and connected to VR, as appropriate, in a timely manner. Set measurable goals for success in timely connections and smooth referrals.
Identified best practices include: LEA’s and VR conferring at least one time per year to identify students who may require VR services, those requiring a VR counselor to attend their case conference, providing “VR 101” refreshers to school personnel, and a follow-up process for VR referrals.
Training for VR staff is planned for 2020 to revisit best practices and expectations regarding transition activities. VR counselors and/or area supervisors are also involved in local transition councils if they exist in the community. Councils are made up of local stakeholders who are involved in the transition from school to work and adult life. Councils could include, but not limited to, students/family, school personnel, and service providers. In addition, VR is responsible for providing written information to students and their families regarding adult services.