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  • Program-Specific Requirements for State Vocational Rehabilitation (Combined or General)

    The Vocational Rehabilitation (VR) Services Portion of the Unified or Combined State Plan must include the following descriptions and estimates, as required by sections 101(a) and 606 of the Rehabilitation Act of 1973, as amended by title IV of WIOA.

    • i. Comprehensive System of Personnel Development.

      In accordance with the requirements in Section 101(a)(7) of the Rehabilitation Act, the VR agency must develop and maintain annually a description (consistent with the purposes of the Rehabilitation Act) of the VR agency’s comprehensive system of personnel development, which shall include a description of the procedures and activities the State VR agency will undertake to ensure it has an adequate supply of qualified State rehabilitation professionals and paraprofessionals that provides the following:

i. 3. Standards that are consistent with any national or State-approved or -recognized certification, licensing, registration, or other comparable requirements that apply to the profession or discipline in which such personnel are providing VR services; and

  • A. Standards that are consistent with any national or State-approved or -recognized certification, licensing, registration, or other comparable requirements that apply to the profession or discipline in which such personnel are providing VR services; and

  • B. The establishment and maintenance of education and experience requirements, in accordance with section 101(a)(7)(B)(ii) of the Rehabilitation Act, to ensure that the personnel have a 21st century understanding of the evolving labor force and the needs of individuals with disabilities.

Current Narrative:

A. Standards that are consistent with any national or State-approved or -recognized certification, licensing, registration, or other comparable requirements that apply to the profession or discipline in which such personnel are providing VR services

While Indiana BRS does not require any specific certification, licensing, or registration, BRS has several staff who are Certified Rehabilitation Counselors (CRC). There are currently 17 VR staff who hold a CRC, with 4 additional staff enrolled in master’s in rehabilitation counseling programs who plan pursue the CRC credential. Of the 200 current VR counselor positions, 5 have their CRC. VR also has 2 certified region managers, 5 certified area supervisors, and 5 individuals on the Central Office team who are CRC’s. As there are no CACREP accredited rehabilitation programs in Indiana, BRS modified the minimum VR Counselor qualifications to ensure a sufficient talent pipeline to fill VR Counselor positions. Those minimum qualifications are detailed below under item B of this section of the state plan. As many VR Counselors do not come to BRS with a Rehabilitation degree, BRS has built a robust training process to ensure that new VR Counselor training fills any education gaps. Those training requirements are outlined throughout this section of the state plan.

B. The establishment and maintenance of education and experience requirements, in accordance with section 101(a)(7)(B)(ii) of the Rehabilitation Act, to ensure that the personnel have a 21st century understanding of the evolving labor force and the needs of individuals with disabilities.

Current VR Counselor qualifications are as follows:

Master’s degree from an accredited university in rehabilitation counseling, rehabilitation administration, counseling and guidance, social work, special education, sociology, audiology, education, speech pathology, or a closely related human service area or certification as a Certified Rehabilitation Counselor (CRC) is preferred;

OR

In lieu of a master’s degree, a bachelor’s degree from an accredited university in rehabilitation counseling, rehabilitation administration, counseling and guidance, social work, special education, sociology, psychology, audiology, education, speech pathology, or a closely related human service area or certification as a Certified Rehabilitation Counselor (CRC); AND

Demonstrated paid or unpaid experience, for not less than (1) one year, consisting of:

  • Direct work with individuals with disabilities in a setting such as an independent living center;
  • Direct service or advocacy activities that provide such individual with experience and skills in working with individuals with disabilities; or
  • Direct experience as an employer, as a small business owner or operator, or in self-employment, or other experience in human resources, recruitment, or experience in supervising employees, training, or other activities that provide experience in competitive integrated employment environments.

Other preferred experience includes:

  • Vocational counseling skills, motivational interviewing skills, or related counseling skills
  • Awareness of cultural diversity, medical and psychological aspects of disability, counseling theories, assessment tools, job development and placement, Rehabilitation Act, ADA, IDEA, Social Security, Medicaid, Medicare, other state/federal programs, DWD programs, rehabilitation technology, economic and labor market trends, community organizations, and financial aid.
  • Excellent oral and written communication skills, creativity, problem-solving, evaluation of services, and time management skills.
  • Ability to communicate with diverse populations, flexibility, handling multiple tasks, maintaining professional demeanor, and ability to empathize.
  • Ability to interpret psychological/medical evaluation reports and medical terminology.
  • Familiarity with Assistive Technology and how to access AT services.
  • Knowledge of local community and statewide resources preferred.
  • Knowledge of local and statewide job market preferred.
  • Willingness to obtain necessary continuing training/education for CRC maintenance, or if not a CRC willingness to work toward becoming eligible to sit for CRC examination.

Since there are no accredited rehabilitation education programs in the state, BRS identified a need to modify VR Counselor minimum qualifications as outlined above to ensure a sufficient pipeline of qualified applicants. To sustain a high-quality VR Counselor workforce, the training process for new Counselors has also been enhanced, along with continuing education requirements for all VR Counselors, to ensure staff stay up-to-date on the evolving needs of individuals with disabilities. Individuals hired as VR Counselors that do not have a master's degree in Rehabilitation Counseling or CRC must complete a robust training process, with oversight by the VR Training Team and the local Supervisor. These staff enter as VR Counselor Trainees and perform their work under the supervision of the VR area supervisor or VR working lead Counselor until they have completed initial training and demonstrated the necessary progression in performance of VR Counselor responsibilities to promote to a VR Counselor. They are required to complete 70 clock hours of asynchronous online courses to include, but not limited to, medical and psychological aspects of disability; rehabilitation counseling theory, strategies and techniques; benefits counseling; and assistive technology.  Trainees must demonstrate satisfactory completion of these training requirements and satisfactory performance prior to transitioning out of the VRC Trainee role and into the VR Counselor role. This is assessed by the Supervisor and reviewed with the Region Manager at around 8 months from the VR Counselor Trainees start date. The review can be extended for another 3-6 months if training requirements have not been met or satisfactory competency in performing their responsibilities has not been demonstrated.

In addition, VR Counselor Trainees must demonstrate satisfactory counseling and guidance skills through participation in a Counseling and Guidance Cohort, a small group in which Trainees put their newly acquired skills into practice using scenarios and role play exercises, during their first year of employment. The Counseling and Guidance Cohorts are conducted under the supervision of individuals who hold a graduate degree in Rehabilitation or other counseling area, or is certified or licensed as a counselor.

Additionally, all VR Counselors including seasoned staff, are required to complete a minimum of 12 clock hours annually for professional development activities as appropriate and approved by their supervisor.

Through the VR staffing structure outlined in this section including the designation of VR Counselor Trainee from VR Counselor and the designated VR Counselor Specialty roles, e.g., Intake/Eligibility Counselor v. Caseload Counselor; the robust initial training for Trainees; Counseling and Guidance Cohorts; and ongoing professional development for all VR Counselors and Supervisors, VR Counselors are qualified to perform their responsibilities, including non-delegable functions and the authorization and delivery of high quality vocational rehabilitation services. BRS VR Counselors are qualified personnel for purposes of the determinations that must be made in accordance with 34 CFR 361.42(a)(1)(i) and (ii), i.e., that the applicant has a physical or mental impairment, and that the physical or mental impairment constitutes or results in a substantial impediment to employment.  VR Counselor Trainees, who are not yet considered to meet the standards as qualified personnel, work under the direct supervision of qualified personnel who will review and approve all of their eligibility determinations.

The current hiring qualifications were put into place shortly following the passing of WIOA legislation. VR initially experienced an increased number of qualified applicants for VR Counselor vacancies as well as improved retention. However, with the continuous drop in the unemployment rate and increasingly competitive job market, recruitment challenges continued for several years following WIOA implementation. Over the last year, BRS has experienced much greater success in recruiting qualified applicants, likely attributed to salary increases and other initiatives as described above.