COUNCIL OF STATE ADMINISTRATORS OF
VOCATIONAL REHABILITATION
PRINCIPLES FOR THE CSAVR DURING THE 2003
REAUTHORIZATION OF THE REHABILITATION ACT
( May 16, 2002 )
This paper outlines the guiding principles that the Council of State Administrators of Vocational Rehabilitation (CSAVR) believes must continue to be the foundation of Title I of the Rehabilitation Act to ensure that individuals with disabilities continue to have access to the highest quality job training and employment services and supports tailored to their unique and individualized needs. Among other things, these principles emphasize employment and economic self-sufficiency as the intended outcome of vocational rehabilitation services. They emphasize the consumer focus of the Public Vocational Rehabilitation (VR) Program, including an emphasis on informed choice and individualized services and supports. The principles acknowledge that individuals with disabilities can and do work in the competitive labor market. The need to ensure the adequacy of VR’s resources, the dedicated nature of VR funding, the integrity of the State Unit designated to provide VR services, the accountability of the Public VR Program, and the use of qualified personnel are also addressed in these principles. The principles also emphasize strengthening transition services, establishing partnerships with other service providers; and promoting the accessibility of all service providers. The Council believes that the opportunity to secure meaningful employment in the competitive labor market can only be assured for individuals with significant disabilities when the States maximize the use of the knowledge and expertise of the qualified professionals currently staffing State Vocational Rehabilitation (VR) Agencies.
The Council is composed of the chief administrators of the State VR Agencies serving individuals with physical and mental disabilities in the states, District of Columbia , and the territories. These agencies constitute the state partners in the State-Federal program of rehabilitation services authorized under Title I of the Rehabilitation Act of 1973, as amended. In any given year, the Council’s member agencies supervise the rehabilitation of approximately 1.2 million individuals with disabilities. Of those served each year, over 230,000 enter competitive employment.
The Council, which was founded in 1940 to furnish input into the State-Federal Rehabilitation Program, provides a forum for state administrators to study, deliberate, and act upon matters affecting the rehabilitation and employment of individuals with disabilities. The Council serves as a resource for the formulation and expression of the collective points of view of State VR Agencies on all issues affecting the provision of quality employment and rehabilitation services to persons with mental and physical disabilities.
For individuals with disabilities, who each day face enormous social, economic, and environmental obstacles there are no more important and beneficial programs than those authorized and funded under the Rehabilitation Act. Today, America has a number of new and pressing priorities; however, the freedom and independence of all American citizens must rank among the highest of those priorities. For millions of Americans with disabilities, their freedom and their independence is dependent upon making the Public VR Program a national priority.
PRINCIPLES FOR THE CSAVR DURING THE 2003
REAUTHORIZATION OF THE
REHABILITATION ACT
Emphasis on Employment and Economic Self-Sufficiency
While recognizing the importance of independent living services, professional development, and rehabilitation research and training programs, and the ultimate contribution that these related services have to the overall goal of expanding employment opportunities for individuals with disabilities, any changes to provisions in Title I of the Rehabilitation Act must continue to ensure that "employment and economic self-sufficiency" is the primary goal of the provision of VR services. In keeping with this goal, CSAVR supports the continuation of efforts to streamline the administration of the program to the fullest extent possible to emphasize successful employment outcomes. CSAVR also believes that, with the exception of Title VII, the other programs, projects and services authorized under the Rehab Act should also maintain an emphasis on employment and economic self-sufficiency.
Presumption of Benefit
Individuals with disabilities, including
individuals with the most significant disabilities, are generally presumed to be
capable of engaging in competitive employment. This is a value unique to
the Public VR Program and distinguishes this program from all other employment
and training programs, both public and private. This principle reinforces
the fact that individuals who meet the eligibility requirements of the Public VR
Program can be successfully employed and can benefit from the provision of
individualized vocational rehabilitation services and supports delivered by
State VR Agencies in terms of real, and meaningful, integrated, competitive
employment.
Consumer Focus
The planning and implementation of the Public VR Program must continue to provide adequate opportunities for the effective and meaningful involvement of consumers in the State Plan process, in the conduct of public hearings, and in the functioning of the State Rehabilitation Council (SRC) or the independent commission overseeing the operation of the Public VR Program. To assure public accountability, the SRC or the independent commission must continue to be a public entity whose members are appointed by the Governor or other appointing authority in the State. A mechanism must be in place to ensure the timely appointment of new members when vacancies occur on the SRC or the independent commission.
Emphasis on Informed Choice
The CSAVR believes that Title I of the Rehabilitation Act must continue to emphasize informed choice throughout the rehabilitation process. Each eligible individual with a disability must continue to have an informed choice in the selection of his/her vocational goal/employment outcome; in the services and supports needed to accomplish the individual’s chosen vocational goal/employment outcome; and in the providers of those services.
Individualized Services and Supports
The CSAVR believes that all direct services provided to eligible individuals under Titles I and VI of the Rehabilitation Act must be individualized based on the unique strengths, resources, priorities, concerns, abilities, capabilities, and interests of those individuals. Individualized services include the provision of appropriate support services, including accommodations, assistive technology devices and services, and personal assistance services, which are necessary to facilitate assessments and evaluations, and maximize the benefits of training programs. CSAVR believes that qualified vocational rehabilitation counselors and their collaborative relationships with consumers of the Public VR Program constitute the cornerstone of the rehabilitation process. Using their skills in medical and vocational assessment and their knowledge of labor market information, qualified vocational rehabilitation counselors assist eligible individuals to select employment goals and identify the services, supports and resources needed to achieve those goals.
Adequacy of Resources
Real and significant increased funding is required to maintain and enhance the quality of services provided by State VR Agencies and to facilitate employment outcomes for individuals with disabilities. The CSAVR believes that the Public VR Program must have substantially increased resources to meet the unique and specialized rehabilitation needs of individuals with disabilities. A substantial increase in the federal investment in this proven program must become a national priority. The mandated Consumer Price Index (CPI) increase in funding for the Public VR Program is an important provision in current law that should be maintained in the upcoming reauthorization. However, Congress must understand that this mandated CPI increase represents the minimum annual increase in federal funding for the VR Program, and that increases in the overall federal appropriation must be adequate to ensure that each state allotment gets at least an increase equal to the CPI increase for the previous year. The CSAVR believes that such increases are necessary if State VR Agencies are to meet the performance standards and indicators developed by the Rehabilitation Services Administration, to keep up with the demands and expectations of people with disabilities, to address increased demands resulting from the impact of the Workforce Investment Act, the Ticket to Work Program, Temporary Assistance for Needy Families (TANF), transition initiatives, and assistive technology demands, and to significantly increase the number of individuals with disabilities achieving high quality employment outcomes.
Cost containment associated with administrative efficiencies cannot sustain the current level of service being delivered under Title I of the Act. During FY 2002, thirty-seven VR agencies found it necessary to implement an order of selection, a mandated system of prioritization whereby only those eligible individuals with the most significant disabilities receive VR services. In those states, significant numbers of eligible individuals with disabilities who would normally receive services through the Public VR Program will not be served due to insufficient resources.
Preservation and Expansion of Funding Dedicated to Meeting the Unique Needs of Individuals with Disabilities Eligible For Services Under Title I of the Rehabilitation Act
The CSAVR will strongly oppose any attempt to waive the requirements of Title I of the Rehabilitation Act, to block grant VR funding, or to co-mingle funding available under Title I of the Rehabilitation Act with other funding streams to provide employment and training services to populations other than individuals with disabilities. All funds authorized under Section 110 of the Rehabilitation Act must continue to be available for the express purpose of providing services and supports to individuals with disabilities who are applying for or eligible to receive services to assist them in entering, re-entering, or maintaining gainful employment.
The CSAVR strongly supports the continuation of a dedicated funding stream that can be used only to determine whether individuals with disabilities are eligible for services under Title I of the Rehabilitation Act and to provide comprehensive employment, training and support services to eligible individuals through the sole state agency designated to administer the State Plan for vocational rehabilitation services under Title I of the Rehabilitation Act of 1973, as amended. While CSAVR strongly supports significant increases in Title I funding, the Council does not support reducing funding to or eliminating other programs funded under the Rehabilitation Act (e.g., Projects with Industry and Supported Employment State Grants) to secure increases in VR funding.
Integrity of the Designated State Unit
The CSAVR believes that the
continuation of a designated State Unit in each state is absolutely necessary to
ensure that individuals with disabilities continue to have access to the highest
quality job training and employment services and supports tailored to their
unique and individualized needs. The CSAVR believes that the
Rehabilitation Act must continue to require each state to designate in its State
Plan a State Unit that has the sole responsibility for administering the State
Plan for Vocational Rehabilitation Services. However, States may choose to
designate a separate State Agency or Unit to serve individuals who are blind or
visually impaired. Each designated State Unit must be an agency or a
division within a state agency that is primarily concerned with the provision of
vocational rehabilitation services and supports to individuals with
disabilities; has a full-time director; employs staff who are engaged at least
90 percent of the time on the vocational rehabilitation of individuals with
disabilities; and have organizational responsibilities equal to other major
organizational units within state government. Services through the
designated State Unit must be available on a statewide basis. CSAVR
believes that development of the budget, management of finances, supervision of
staff, determinations of eligibility, approval of individualized plans for
employment, and documentation of case closures should be the sole responsibility
of qualified professionals employed by designated State Units, as should the
overall management of the VR program. State-level oversight and
accountability will ensure a strong Public VR Program. Holding to these
requirements will protect the integrity of the Public VR Program and ensure that
State VR Units are viable, accountable, and effectively managed to ensure the
highest level of service to individuals with disabilities.
Accountability
The CSAVR believes that accountability is a fundamental, critical element of the Public VR Program, particularly regarding the expenditure of public funds and the provision of vocational rehabilitation services. The Standards and Indicators required in the Rehabilitation Act provide important measures of performance. At both a federal and state level, the Public VR Program has demonstrated its cost effectiveness in achieving employment outcomes for eligible individuals with disabilities through the provision of vocational rehabilitation services. CSAVR supports ongoing research efforts that provide accurate and timely performance data such as A Longitudinal Study of the Vocational Rehabilitation Service Program. Efforts such as this objectively review and report on the Public VR Program’s effectiveness.
Use of Qualified Personnel
The CSAVR believes that the Rehabilitation Act must continue to require each state to apply to its staff the highest personnel requirements that exist in the State and that apply to each profession, while providing the State VR Agency with a necessary degree of flexibility to recruit, retain and develop staff in achieving this personnel standard. The use of the highest personnel standards will ensure the availability of effectively trained and highly competent staff to provide services throughout the rehabilitation process. Qualified rehabilitation personnel assure the delivery of specialized services and supports not available from the personnel of generic employment and training programs. Research indicates that individuals receiving services from qualified rehabilitation personnel derive greater benefit from the vocational rehabilitation program. To ensure an adequate supply of qualified rehabilitation personnel, the CSAVR supports increased resources to recruit and retain qualified staff.
Emphasis on Transition
As State VR Agencies throughout the nation are increasingly focused on helping people with disabilities find quality employment that will lead to self-sufficiency, students with disabilities who are leaving the education system represent the single largest source of potential customers for VR services. The federal appropriation for special education increased by approximately 140 percent between 1997 and 2002 while the appropriation for the Public VR Program increased by only the mandated annual Consumer Price Increase (CPI). Enrollment in special education also increased significantly during this time period. As a result, State VR Agencies are finding it increasingly difficult to meet the needs of students with disabilities who are transitioning from special education and seeking services and supports to become gainfully employed.
CSAVR believes it is critical that all State VR Agencies strengthen the continuum of services provided to these students to facilitate a much smoother, more beneficial transition from the secondary education system to adult services, including VR services. As part of this effort, CSAVR supports the development of an outreach program designed to educate students and their families as well as community partners about the services and supports State VR Agencies can provide to help students with disabilities prepare for their entrance into the job market. In addition, CSVAR believes that the creation of an on-going, productive dialogue among students with disabilities and their parents, secondary education staff, and State VR Agency staff is necessary to facilitate every student's successful transition from school to quality competitive employment that provide a living wage and an opportunity to move up the career ladder.
Emphasis on Partnerships
The CSAVR believes that the State VR Agency is the best-equipped public agency to provide the specialized services and supports that individuals with disabilities may need to enter, re-enter or maintain employment. In the new era of the Workforce Investment Act and the Ticket to Work Program, State VR Agencies must have a strong presence and assume a leadership role in working with other components of the workforce investment system, while maintaining the integrity of the Public VR Program. It is important that the director of the Designated State Unit and the Agency for the Blind, if separate, be required members of the State Workforce Investment Board. Such a presence is critically important to ensure the full participation of individuals with disabilities in workforce investment activities. State VR Agencies must also continue to enhance their collaboration with state education agencies and local education agencies to ensure that eligible students with disabilities can transition smoothly to the world of work. State VR Agencies are well equipped to play an important and unique role in working with the other components of these service delivery systems by providing technical assistance on how to accommodate functional limitations and how to make programs and facilities accessible to individuals with disabilities, and by providing opportunities for staff from these other programs to participate in specialized training programs offered to VR staff.
Accessibility of Job Training Programs, Educational Programs and Other
Service
Programs
The CSAVR feels it is extremely important to emphasize the fact that service providers, including educational institutions, have the primary responsibility to make their services accessible to all individuals, including eligible participants in the Public VR Program. Under the Americans with Disabilities Act (ADA), generic service providers, including One-Stop centers created under the Workforce Investment Act of 1998, are responsible for serving individuals with disabilities under the same terms and conditions as they serve non-disabled individuals, and for providing the necessary accommodations to ensure the meaningful participation of such individuals in educational and training programs and in employment. All educational, vocational education, job training and employment services provided by generic service providers should be completely accessible to individuals with physical, mental, sensory and cognitive disabilities. Where necessary, appropriate individualized accommodations must be available to facilitate participation of such individuals in generic services programs. While VR staff may assume the role of providing technical assistance on how to identify and provide needed accommodations and how to make physical facilities accessible to individuals with different types of disabilities, State VR Agencies should not be asked to cover the expenses associated with making One-Stop facilities and programs accessible to the individuals with disabilities or for the accommodations necessary for students with disabilities to participate in higher education programs. In addition, State VR Agencies should not be asked to assume the expenses associated with the provision of core services in a One-Stop center merely because some individuals with disabilities will be benefiting from those services.
Representation of Disability Interest on Workforce Investment Boards
Recognizing the expertise of individuals staffing State VR Agencies and the importance of considering the views of individuals with disabilities, the CSAVR believes each State Workforce Investment Board (SWIB) must include in its membership at least one individual with a disability and the Director (s)/Administrator(s) of the Designated State Unit(s) administering the Public VR Program or an individual designated by the Director (s)/Administrator(s). The representative of the Designated State Unit must be a person who has day-to-day responsibility for administering the Public VR Program. Nearly four years after implementation of the Workforce Investment Act (WIA), there are still states that are meeting the SWIB composition requirements by having the head of the umbrella agency housing the Public VR Program serve as the VR representative on the SWIB. In addition, while WIA requires Local Workforce Investment Boards to include representatives of local community-based organizations (including organizations representing individuals with disabilities and veterans), no such requirement is applied to the SWIB. Since these State Boards set the parameters within which the Local Boards must operate, it is critically important that the needs of individuals with disabilities are adequately represented on all SWIBs.
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