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j. 2. Identify the need to establish, develop, or improve community rehabilitation programs within the State; and

Current Narrative:

While the findings of the 2017 CSNA do not suggest the need to establish further community rehabilitation programs within the state, changes underway that concern implementation of the Workforce Innovation and Opportunity Act make clear the need for certain developments and improvements. Since passage of WIOA in 2014, ADRS has worked closely with its Community Rehabilitation Program partners to adjust and implement WIOA’s historic mandate. Influencing these historic changes are:

• Regulations on Transition Services and Pre-Employment Transition Services
• Regulations on Employment Outcomes and Competitive Integrated Employment
• Regulations on Supported Employment
• Regulations concerning VR Performance Indicators
• Regulations on Section 511 and Limitations on Use of Sub-Minimum Wage

The process of re-allocating our resources with the CRP program has already begun with Pre-Employment Transition Services and so far is considered a success. Of the total CRP set-aside dollars authorized to date in FY 17, 33% is for Pre-ETS service. Of all the consumers who had an authorization in the set aside, 44% of these were students with disabilities. The provision of Pre ETS through CRPs is an essential component of the department’s plan to meet the needs of students with disabilities. In order to continue at this pace and to provide the services our consumers need to become better equipped to work, the method of payment for services provided by the CRP needs to transition from a performance or outcome based system as in STEPS I, II, and III to a service based system as we have done with Pre-ETS. It is proposed that these services be phased in as the CRP becomes prepared to provide them and meet the demands of the counselors. However, most of the CRP’s are already equipped to or are providing these services.

The restrictions placed on access to sub-minimum wage and the expansion of supported employment opportunities are significant but not particularly new in the VR program. Sheltered employment at below minimum wage has not been a suitable outcome for VRS for almost 20 years. WIOA simply made it much more difficult for a person to by-pass VR and select sub-minimum wage employment. Most of the traditional community rehabilitation partners in the state have relinquished their Department of Labor (DOL) sub-minimum wage certificates in favor of paying at least the minimum wage in what was traditionally called “sheltered employment”. With supported employment, the law places an emphasis on providing services to youth with disabilities and for providing extended supports for a longer period of time before the ongoing support is transitioned from VR to another provider.

Counselors are being trained on the new WIOA initiatives and requirements. An emphasis is being placed on providing services that will make a person more capable of getting and maintaining a job than they were when they applied for VR services. This might include sponsorship in vocational, technical, or post-secondary training. It may include purchase of and training in the use of adaptive equipment or adaptive driving to overcome employment barriers. Or it may involve a referral to a CRP for job readiness, Smart Work Ethics, transitional employment, vocational assessment, work adjustment, career assessment, paid work experience, on the job evaluation or any other number of services to prepare and orient a consumer to the demands and skill requirements of work.

The WIOA performance indicators which will now be imposed on VR programs have been utilized for many years by our DOL partners. These performance indicators place a greater emphasis on employment retention and earnings after the employment outcome has been achieved. While VRS will still be judged on persons who maintain employment for 90 days and are closed as successfully rehabilitated, equal or greater weight will be given to whether that person has maintained employment for up to a year after services have been discontinued. Median earnings of all persons who retain employment is also a new standard for VR. These two indicators are intended to bring about a change in the services rendered to consumers. AVRS requires CRP partners who are committed to outcomes in which consumers maintain employment and earn a living wage.