American Counseling Association Reauthorization of the Rehabilitation Act Testimony
Statement for U.S. Department of Education, Office of Special Education and Rehabilitative Services, Rehabilitation Services Administration
Public Meeting on the Reauthorization of the Rehabilitation Act of 1973 as Amended
- Submitted June 19, 2002 -
*On behalf of the American Counseling Association, thank you for hosting this meeting regarding the reauthorization of the Rehabilitation Act (Rehab Act) of 1973 as amended.
Founded in 1952, the American Counseling Association (ACA) represents over 55,000 professional counselors across the country and is the world's largest private, non-profit organization representing professional counselors. Professional counselors are master’s degreed health and social services providers and work in a variety of areas including schools, clinics, community agencies, military bases, correctional facilities, and rehabilitation centers. ACA has 18 divisions, including the American Rehabilitation Counseling Association (ARCA), whose mission is to enhance the development of persons with disabilities and to promote excellence in the rehabilitation counseling profession.
Over the years, ACA and ARCA have worked with the Rehabilitation Services Administration (RSA) and Congress to develop and improve rehabilitation policy. Last month, organizational representatives met with Commissioner Wilson and RSA staff to discuss our concerns and hopes for the reauthorization of the Rehab Act. ACA appreciated that opportunity.
Rehabilitation counselors are the backbone of the state-federal vocational rehabilitation (VR) program. Their specialized knowledge of disabilities, workforce development, labor markets, employers, and counseling skills make the rehabilitation counselor unique. Rehabilitation counselors need this expertise in order to effectively serve individuals with a variety of disabilities, including increasingly more individuals with multiple or severe disabilities.
Rehabilitation counselors provide individualized services to maximize the employability, independence, and integration of people with disabilities into the workplace by ensuring informed choice and facilitating client empowerment. Typical services include assessment of rehabilitation needs, development of an individualized plan to meet those needs, coordination of the array of services, job placement, and follow-up to assure that the goal was achieved.
The rehabilitation counselor is the central professional responsible for the delivery of rehabilitation services to persons with disabilities and the primary fiscal agent responsible for expenditure of tax funds in the rehabilitation process. It is therefore vital that the Rehabilitation Act continues to require that persons hired as rehabilitation counselors posses the appropriate expertise, certification and academic credentials necessary to be qualified vocational rehabilitation counselors. To this end, ACA supports maintaining and strengthening the Comprehensive System of Personnel Development (CSPD) requirements which ensure delivery of high quality services to people with disabilities by recognizing that specialized training is necessary to provide vocational rehabilitation services. Research has proven that better client employment outcomes can be achieved when they are served by qualified rehabilitation counselors. Further, research has also proven that qualified rehabilitation counselor’ services are more efficient and cost effective.
In 1999, the 25th Institute on Rehabilitation Issues (IRI) produced a report entitled, "Achieving Employment Outcomes through VR Counselors Who Meet the Comprehensive System of Personnel Development Requirements". ACA was honored to help participate in the development of that publication that offered insight into the complex, but vital task of hiring, training, and retaining qualified rehabilitation counselors. ACA urges RSA to use the publication as both a tool and resource during the reauthorization of the Rehabilitation Act. Although the report highlighted many issues, the finding that, "forty-two percent of current staff don't meet the CSPD requirements and many agencies are projecting the loss of a large number of staff due to retirements over the next five years" is most troubling. Clearly, several steps must be taken to remedy this problem.
Rehabilitation counselor recruitment and retention must be addressed during the reauthorization. RSA should consider developing a national strategy to educate, train, and recruit individuals to serve as qualified vocational rehabilitation counselors.
Another necessary step is to strengthen state CSPD implementation requirements and evaluations. Unfortunately, states continue to hire individuals who do not possess the skills and expertise necessary to provide rehabilitation counseling services. Admittedly, States can hire below the standard, when and if necessary, but they are required to develop a plan to help those individuals meet the CSPD standard. This provision should not become a loophole to further circumvent hiring the appropriately qualified staff. State plans need to be more thoroughly evaluated and regulated to meet the standards set forth. Both client and employers satisfaction with the VR program should be evaluated to provide the opportunity for continuous quality improvement of CSPD.
However, any efforts to improve the Rehab Act could be jeopardized by privatization or the recent “superwaiver” proposals. ACA would not support proposals to privatize the state-federal VR programs or the “superwaiver” as part of the reauthorization of the Rehab Act.
ACA was very concerned by Florida’s efforts to privatize the state-federal VR programs and the potential implications for the VR system. During the Florida VR privatization, consumers suffered as services were seriously delayed, disrupted, not provided or discontinued. Following hearings and site visits, RSA found “evidence that clearly points to the steady deterioration of vocational rehabilitation services”. ACA applauds the efforts of RSA to curtail and monitor Florida VR. RSA’s guidance and oversight during this period was instrumental to protect the integrity of the VR program and services to persons with disabilities. ACA hopes that RSA will continue to practice the thorough evaluation and oversight of other issues that impact the state-federal VR program and would support adding provisions in the Rehab Act to facilitate that process.
In closing, thank you for the opportunity to submit comments. ACA looks forward to continuing to work with RSA to improve the Rehabilitation Act.
