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
(May 16, 2002)
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.
5/16/02
