- III. Operational Planning Elements
The Unified or Combined State Plan must include an Operational Planning Elements section that supports the State’s strategy and the system-wide vision described in Section II(c) above. Unless otherwise noted, all Operational Planning Elements apply to Combined State Plan partner programs included in the plan as well as to core programs. This section must include—
- b. State Operating Systems and Policies
The Unified or Combined State Plan must include a description of the State operating systems and policies that will support the implementation of the State strategy described in section II Strategic Elements. This includes—
- b. State Operating Systems and Policies
III. b. 8. Addressing the Accessibility of the One-Stop Delivery System for Individuals with Disabilities
Describe how the one-stop delivery system (including one-stop center operators and the one-stop delivery system partners), will comply with section 188 of WIOA (if applicable) and applicable provisions of the Americans with Disabilities Act of 1990 (42 U.S.C. 12101 et seq.) with regard to the physical and programmatic accessibility of facilities, programs, services, technology, and materials for individuals with disabilities. This also must include a description of compliance through providing staff training and support for addressing the needs of individuals with disabilities. Describe the State’s one-stop center certification policy, particularly the accessibility criteria.
Addressing the Accessibility of the One-Stop Delivery System for Individuals with Disabilities
DEO was one of the original recipients of the Department of Labor’s Disability Program Navigator (DPN) grant in 2002 and has expanded services to people with disabilities at CareerSource Florida career centers throughout the state. The DPN grant focused on developing relationships across agency and entity lines to leverage resources and enhance employment opportunities for people with disabilities. The grant was a catalyst to:
- Expand opportunities and increase staff awareness of the variety of assistive technologies and services available
- Provide technical assistance and training on assisting people with varying disabilities
- Ensure career centers were readily accessible
After the U.S. Department of Labor’s DPN ended, CareerSource Florida awarded state-level funding to LWDBs to support accomplishments of the DPN grant and assist local areas with staffing, purchasing of assistive technology and services and modifications to workstations and offices to better accommodate people with disabilities. The CareerSource Florida center system expanded the range of local partners who provide supplemental services to maximize the success of people with disabilities in the workplace.
LWDBs continue expanding employment and training services for people with disabilities. Eighteen of Florida’s 24 LWDBs have been approved as Employment Networks (EN) under the Ticket to Work program.
The state and several LWDBs have accessible mobile CareerSource Florida career centers that provide onsite services to people with disabilities. These mobile centers provide additional access to remote job fairs, assist those impacted by mass layoffs and provide access to other employment and training events for people with disabilities.
At the state level, the workforce system increased active participation on boards working to improve the quality of life of people with disabilities such as:
- Florida Alliance for Assistive Services and Technology (FAAST)
- Florida Developmental Disability Council-led Employment First Initiative and its Employment and Transportation Task Force
- Community Services Block Grant Advisory Council
- Commission for the Transportation Disadvantaged
The Agency for Persons with Disabilities (APD) has representation within the workforce system and several members of the Statewide Strengthening Youth Partnership are entities focusing on providing quality services to people with disabilities.
VR has been a partner in the CareerSource Florida network since the inception of WIOA. Many other state and local entities provide resources that help to maximize employment opportunities for people with disabilities. These partners enhance services career centers offer customers and provide support the workforce system cannot. Non-core partners and the workforce system maximize comprehensive services for job seekers offering the opportunity for self-sufficiency through meaningful employment.
As noted previously in this report, VR launched the Abilities Work web portal within the state MIS, Employ Florida. The portal was created in response to recommendations made by the Governor’s Commission on Jobs for Floridians with Disabilities. The Abilities Work web portal was developed by DEO in partnership with VR, FDBS, APD, the Florida Developmental Disabilities Council and stakeholders from around the state to provide single point of contact for employers who seek to hire individuals with disabilities. The portal provides guidance and information. The portal’s help desk is operated by VR staff with specialized knowledge in disability resources who can guide job seekers and employers navigating the employment system. DEO and these partners continue monitoring the web portal and make improvements in response to suggestions from users and staff.
Resources described above provide a strong foundation for accessibility in the CareerSource Florida network service delivery system. To support and strengthen existing resources, DEO’s Office of Civil Rights (OCR) conducts regular onsite and desktop reviews of each LWDB’s compliance with the Americans with Disabilities Act (ADA) of 1990, as amended, and 29 CFR Parts 32 and 37.
LWDBs are required to conduct self-audits and participant data analysis to annually monitor their own compliance with the ADA. The primary compliance criteria are contained in Florida’s Methods of Administration, as required by federal equal opportunity regulations. To obtain meaningful information about the level of service provided to people with disabilities, OCR conducts the following reviews as necessary:
- Staff interviews
- Customer surveys and interviews
- Facility accessibility survey review and assessment
- Review of customer informational materials, including materials in alternative formats and languages other than English
- Review of community contact programs
- Observation of center activities
- Complaint file review
- Discussion of intake and assessment processes, including provisions to serve people with disabilities or who are non-English speaking
- Review of compliance monitoring reports prepared by or on behalf of the LWDB
- Review of program and equipment available
OCR provides ongoing technical assistance to LWDB/career center staff on such topics as reasonable accommodation requests from customers and employees. Based on these technical assistance requests and its reviews of LWDBs’ compliance with ADA requirements, OCR provides formal training onsite or on critical topics by webinar.
In 2013, VR introduced a strategic initiative to ensure accessibility of all agency components including programs, facilities, personnel and hiring practices, online resources, internal and external communications, and technology systems. Strategies are now built into VR operational procedures. Following ADA Title II requirements, FDOE Leasing staff conducts ADA inspections of all new or renewed VR office leases. VR offices inspected and found not in compliance have a 504 Plan which describes accessibility improvements planned for the facility. VR customers are included in this process when possible. VR employees in every area are required to complete ADA Coordinator certification training and ADA informational training. Hearing loops and other adaptive equipment and/or software is available in VR facilities. Specific applications were developed using custom JAWS script and workflow documentation to meet the needs of users.
The FDBS has an accessibility team that provides training to staff on creating accessible documents. The team reviews materials and assists other agencies with applying guidelines to ensure their websites are accessible. The Division’s IT team created a detailed resource guide for staff, partners, community rehabilitation providers, etc., covering these topics and more in notable detail. This guide is under review by FDOE leadership. The FDBS is working with a vendor to obtain unlimited licenses for assistive technology (AT) such as JAWS (computer screen reader) and Zoom Text (screen magnifier and voice over). This will allow the Division to provide AT to clients, core partners, and state agencies. The FDBS will also provide licenses to other agencies as requested. Core partners are in mid-stages of establishing a Hub for common intake.
Additional VR internal strategies and activities to increase equal access to individuals requesting services are as follows.
- Use a comprehensive safety plan for monitoring VR facilities statewide. Specific components include a process for reporting defective/unsafe working conditions, safety and facilities management training for area staff, a move manual, a statewide safety manual, statewide first aid information, furniture inspection instructions and a facility security/building access policy at HQ.
- Continue to use interpreters, translators, and VR’s online resources, as well as websites of other partners and stakeholders, to reach underserved populations and increase communication with customers.
- Offer expanded access to services and provide materials and program information in English, Spanish and Haitian-Creole for various agencies, employers, churches, community leaders, health clinics and other settings.
- Continue assigning counselors and consultants to serve specialized populations, such as deaf and hard-of-hearing customers, deaf and blind customers and transition students.
- Collaborate with CareerSource Florida and other career center partners to implement universal design principles into the workforce development system’s facilities and operations, with the intent to include universal design as a separate component of the one-stop career center certification process.