Requesting Feedback Related to State VR Agency Technical Assistance Needs

As part of OSERS’ commitment to rethink its work to ensure that it is in the best position to achieve its mission, the Rehabilitation Services Administration (RSA) is rethinking the way it supports and partners with its key stakeholders to improve employment outcomes for individuals with disabilities.

One aspect of this ongoing work is rethinking how RSA evaluates the technical assistance needs of State Vocational Rehabilitation (VR) agencies and RSA’s strategies for disseminating resources and tools that help State VR agencies provide services to individuals with disabilities and the business community.

Through this blog, RSA is interested in receiving feedback from State VR agencies and stakeholders related to two areas: employer services and career advancement under the VR program. In particular, RSA requests that commenters respond to the following questions:

  1. Do State VR agencies need technical assistance or additional information from RSA related to on-demand training (e.g., online videos) for businesses and other employers related to disability issues?
  2. If so, what topics should RSA specifically address related to on-demand training for businesses related to disability issues and through what mode(s) should RSA provide this technical assistance to State VR agencies?
  3. Do State VR agencies need technical assistance or additional information from RSA related to the provision of career advancement services for individuals with disabilities who are employed?
  4. If so, what topics should RSA specifically address related to career advancement and through what mode(s) should RSA deliver this technical assistance to State VR agencies?

RSA will consider comments submitted to the OSERS Blog through December 5, 2019. We appreciate your thoughtful feedback as we work to maximize employment opportunities for individuals with disabilities.


Note:  To help us in our review, we ask that you only address the questions in the comment section. To protect your privacy and the privacy of others, please do not include personally identifiable information, such as a Social Security number, an address, a phone number or an email address in the body of your comment. Comments containing the aforementioned information, or that do not address the above questions, will not be allowed.

13 Comments

  1. 1. Yes.

    2. State VR agencies and their contracted community rehabilitation providers (CRPs) could use technical assistance on providing on-demand training to businesses on how they can effectively partner with VR and their contracted CRPs in helping clients achieve customized employment outcomes. This technical assistance could be provided by RSA via live webinars that allow for Q&A and providing sample materials about customized employment to provide to employers. A written advisory that is publically available on RSA’s web site would also be helpful.

    State VR agencies could also use technical assistance (via technical assistance advisories, webinars, and case studies) on providing on-demand training to businesses on:
    o establishing and publicizing a confidential reasonable accommodation (RA) process
    o providing RAs to employees per business’ obligations under Title I of the ADA so state VR agencies are not unnecessarily forced to pay for such RAs. VR agency funding should focus on helping people with disabilities find jobs and should only pay for RAs to retain jobs if such an RA presents an undue burden to a business. Perhaps a joint guidance document from both DOJ and RSA would clarify the roles of employers vs state VR agencies in paying for employment RAs.
    o providing RAs so employees with disabilities can access employee trainings
    o how to encourage self-identification
    o addressing teasing in the workplace and when it crosses the line to harassment for people with disabilities
    o training people with disabilities for management positions
    o adding performance measures that cover how employees improve morale to increase productivity

    3. Yes.

    4. State VR agencies could use technical assistance on providing training to field staff to ensure counselors understand that advancement in employment (whether in current employment or into new employment) is a legitimate employment outcome under federal regulations and should be encouraged to maximize a client’s employment potential. This technical assistance would be provided in a written advisory that is publically available on RSA’s web site.

  2. 1. Yes.

    2. State VR agencies and their contracted community rehabilitation providers (CRPs) could use technical assistance on providing on-demand training to businesses on how they can effectively partner with VR and their contracted CRPs in helping clients achieve customized employment outcomes. This technical assistance could be provided by RSA via live webinars that allow for Q&A and providing sample materials about customized employment to provide to employers. A written advisory that is publically available on RSA’s web site would also be helpful.

    State VR agencies could also use technical assistance (via technical assistance advisories, webinars, and case studies) on providing on-demand training to businesses on:
    o establishing and publicizing a confidential reasonable accommodation (RA) process
    o providing RAs to employees per business’ obligations under Title I of the ADA so state VR agencies are not unnecessarily forced to pay for such RAs. VR agency funding should focus on helping people with disabilities find jobs and should only pay for RAs to retain jobs if such an RA presents an undue burden to a business. Perhaps a joint guidance document from both DOJ and RSA would clarify the roles of employers vs state VR agencies in paying for employment RAs.
    o providing RAs so employees with disabilities can access employee trainings
    o how to encourage self-identification
    o addressing teasing in the workplace and when it crosses the line to harassment for people with disabilities
    o training people with disabilities for management positions
    o adding performance measures that cover how employees improve morale to increase productivity

    3. Yes.

    4. State VR agencies could use technical assistance on providing training to field staff to ensure counselors, unit supervisors, and area office directors understand that advancement in employment (whether in current employment or into new employment) is a legitimate employment outcome under federal regulations and should be encouraged to maximize a client’s employment potential. This technical assistance would be provided in a written advisory that is publically available on RSA’s web site.

  3. 1. Do State VR agencies need technical assistance or additional information from RSA related to on-demand training (e.g., online videos) for businesses and other employers related to disability issues?

    Yes. Over the last several years, on-demand training and information in various modalities has become increasingly available to State VR agencies for use with businesses related to disability and employment. Federally funded technical assistance regarding employer engagement has been very helpful as well in achieving a dual VR customer focus of employer and job seeker with a disability.

    2. If so, what topics should RSA specifically address related to on-demand training for businesses related to disability issues and through what mode(s) should RSA provide this technical assistance to State VR agencies?

    Future technical assistance that assists State VR agencies to determine their effectiveness in serving employers as a statewide WIOA measure would be beneficial. This could include evaluating the types of training and information provided, as well as specific services and performance outcomes.

    3. Do State VR agencies need technical assistance or additional information from RSA related to the provision of career advancement services for individuals with disabilities who are employed?

    Yes.

    4. If so, what topics should RSA specifically address related to career advancement and through what mode(s) should RSA deliver this technical assistance to State VR agencies?

    Best practices and guidelines for VR counselors to consider in working with individuals with disabilities, including return on investment of advanced education and other factors, would be helpful to State VR agencies. Also, strategies related to the importance of embarking on career pathways as early as possible to open up real opportunities for advancement, such as in the STEM fields, would be of interest.

    This technical assistance could be provided through official guidance, sponsored webinars or other universal access means.

  4. 1. Yes, State VR agencies definitely need assistance. First, generally, VR agencies need a reminder that it is their responsibility to provide such services. Reinforcement of this responsibility from RSA would be helpful. Additionally, the unemployment rate for people with disabilities remains woefully high so the issue needs to continue to be addressed from all possible angles.

    2. Topics to specifically address include tax credits and other incentives for employers who hire people with disabilities, customized employment, disability awareness tools and resources aimed at reducing the stigma that still surrounds many people with disabilities in the work place, as well as non-traditional hiring practices and accessible hiring practices. Training about the availability of reasonable accommodations, including assistive technology and the tremendous resources available from the Job Accommodation Network (JAN) would be beneficial. It would be best if RSA could provide this information in a mode that will enable State VR agencies to quickly begin getting the information out to employers.

    3. Yes, State VR agencies need to be provided with this information on a recurring basis. Many VR agencies are still struggling with the overall concept of “career advancement” and are incorrectly focused on entry-level employment options.

    4. As mentioned above, it begins with an overall mindset shift – all individuals, even those with the most significant disabilities, are capable of career advancement. Some training about available Science, Technology, Engineering and Math (STEM) career options as well as more information about the changing job economy of the 21st century would be helpful. Additional information about the appropriateness of VR funding for college and advanced (master’s and above) degrees would be beneficial.

  5. The Virginia Department for Aging and Rehabilitative Services (DARS) appreciates the opportunity to provide input on technical assistance for employer services and career advancement in the vocational rehabilitation (VR) program to the Rehabilitation Services Administration (RSA). In response to the questions posed, DARS would find it very helpful to receive additional technical assistance regarding employer services and career advancement services.

    For employer services, technical assistance on helping businesses realize the value of hosting internships and other work-based learning activities for students with disabilities is needed. This would help facilitate businesses sharing their hiring needs with state VR agencies and areas that are lacking in the current labor force (for example, soft skills). This information would assist VR agencies, providers, and schools in preparing the future workforce to meet the needs of businesses.

    Additional information and technical assistance in the following areas regarding career advancement would also be helpful:
    • Training and examples of IPEs that support career advancement;
    • Suggested framework for state vocational rehabilitation agencies to support individuals that need a job to meet their immediate needs and support with career advancement;
    o For those who need intensive assistance with both immediate job attainment and career advancement, would it be appropriate to support obtaining a job given current skills/abilities, closing that case successfully and immediately opening another case focused on training/credential attainment to enable career advancement?
    • Webinars, guidance documents, case examples and TA from TA Centers are useful;
    o Webinars that include interactive components, like multiple choice questions woven throughout to keep the audience engaged are more effective than webinars that solely utilize presenters;
    • Information and examples to help state VR agencies better conceptualize how to truly support career advancement, what the continuum of services ideally looks like/how to stack the services, and how to support someone with more intensive needs with an advancement plan that works for them;
    • Best practices and technical assistance in working with employers in all career phases from apprenticeships to career advancement of clients; and
    • Guidance on the parameters of career advancement services. For example, the VR agency assists someone through nursing school and they become employed as a registered nurse. They then decide they want to pursue medical school. What options does the VR agency have in serving this individual?

    In summary, additional guidance would be greatly appreciated and would help facilitate the provision of more effective services to VR clients. Thank you for this opportunity to comment and we look forward to the dissemination of additional information.

  6. 1. Do State VR agencies need technical assistance or additional information from RSA related to on-demand training (e.g., online videos) for businesses and other employers related to disability issues?
    Yes

    2. If so, what topics should RSA specifically address related to on-demand training for businesses related to disability issues and through what mode(s) should RSA provide this technical assistance to State VR agencies?
    *Mode can be short archived webinar, flyer with information, best/promising practice information
    *There are many resources available but may be difficult for staff and employers to know where to go. Perhaps a few short and targeted on-demand training sessions that provide high level information (low cost of accommodations, dispelling myths, ADA, etc. with citations) and resource links for more information if desired.
    *A single document with major resource links and brief description (JAN, EARN, NET, US Chamber (dispelling myths article), PEAT, DMEC, etc.)
    * Perhaps links to Accenture articles on disability and workforce inclusion

    Do State VR agencies need technical assistance or additional information from RSA related to the provision of career advancement services for individuals with disabilities who are employed?
    Yes

    If so, what topics should RSA specifically address related to career advancement and through what mode(s) should RSA deliver this technical assistance to State VR agencies?
    *On demand, short webinar style – perhaps a series depending on amount of information or best/promising practice information
    *Career Advancement from a VR eligibility standpoint
    *Braiding funding with business to support career advancement

  7. 1. Do State VR agencies need technical assistance or additional information from RSA related to on-demand training (e.g., online videos) for businesses and other employers related to disability issues?

    We suggest that RSA consider developing a technical assistance strategy that assesses whether or not and what kinds of on-demand training are effective for businesses and other employers related to disability issues and create guidance on how to invest in effective on-demand training for businesses. ODEP’s EARN Center, previously funded RSA Technical Assistance Centers, newly funded Innovative Rehabilitation Training Centers, and state VR agencies themselves have or are developing on-demand training for businesses and other employers related to disability issues. What is missing is whether or not any of the on-demand training is effective in helping businesses recruit, hire, accommodate, or retain employees and whether or not on-demand training promotes more partnerships between state VR agencies and businesses. We also suggest it would be helpful to have a nationally unified message about VR and link that message to VR performance outcomes for businesses.

    1. If so, what topics should RSA specifically address related to on-demand training for businesses related to disability issues and through what mode(s) should RSA provide this technical assistance to State VR agencies?
    • Ongoing information/training/TA on business engagement and strategies. VR agencies have been growing business relations units. Yet in many states these units are in early stages of development, are at risk if the agency faces budgetary constraints, and are determining how business relations units interact with field services units.
    • Recruiting and Upskilling Business Relations personnel: Information and Videos that help VR agencies recruit staff to business relations and business account manager positions.
    • Performance Data for Business as Customer: What data should be collected related to business engagement and how to use that data to inform what they are doing, doing well, can do better, etc.
    • Improvement in Adoption and Function of Dual Customer Strategies: VR agencies need information and strategies for enhanced integration between business engagement specialists and VR counselors. Such strategies could be but not limited to cross unit communication, utilizing data, strategic business relationships, and business focused support activities.
    • Development of Long-Term and Sustainable Partnerships with Businesses: How to build and sustain long-term employer services (business engagement/relationships) that go beyond the “placement” orientation of VR.

    2. Do State VR agencies need technical assistance or additional information from RSA related to the provision of career advancement services for individuals with disabilities who are employed?
    • Yes

    3. If so, what topics should RSA specifically address related to career advancement and through what mode(s) should RSA deliver this technical assistance to State VR agencies?
    • Integrate Lessons Learned from RSA Model Demonstrations into TA Agenda: RSA invested in the Career Pathways for Individuals with Disabilities Model Demonstration in NE, KY, VA, and GA. These model demonstrations are ending September 2020. This was a substantial investment by RSA. RSA should consider how lessons learned from these model demonstrations (and perhaps others) are integrated into training and technical assistance efforts across the country. What lessons were learned? Are these transportable? Continuation of Career Pathways or similar projects could benefit VR and their clients.
    • Career advancement as a VR service to jobseekers and incumbent workers: VR has the statutory authority to work with individuals with disabilities in advancing in their careers. Less clear is whether public VR public agencies have “advancement in employment” as a focus area (agency priority); have the capacity/alignment of resources to support career advancement as an agency priority; and the capability (knowledge and skill of staff) to serve these individuals effectively. Agencies may need basic TA on what career advancement services are allowable, and given limited resources, how should VR agencies prioritize clients seeking career advancement services and supports over other employment needs (e.g. job development, job retention). This is especially challenging for states in an order of selection with a wait list. Consideration: Could “Career Advancement Services” for all state VR agencies fall under a separate title similar to the current authority for Supported Employment Services?
    • Communication and outreach around career advancement as a VR service category: If career advancement is to become a core service provided to jobseekers and incumbent workers with disabilities, it will require reframing a client’s view of VR as a one-time service to a career-long engagement that builds on past successes. TA could include:
    o Revising client contact information collection and maintenance of records to enable continued communication;
    o Developing follow-up protocols that go beyond case closure to maintain client engagement with VR with a focus on advancement;
    o Streamlining eligibility and access to services for individuals with advancement support needs so cases can be re-opened without delay or penalty.
    • Career advancement as a dual-customer strategy: VR agencies should consider offering employers services and supports that promote advancement of incumbent workers with disabilities. TA would be required related to:
    o Translating VR eligibility information in a way that resonates with businesses and incumbent workers (especially those who are not familiar with VR), for example: reframing the word “disability”
    o Managing a pipeline of VR applicants generated from business outreach as another entry point to VR
    o Maintaining confidentiality of incumbent workers, and supporting disability disclosure if applicable
    o Developing mechanisms to support employers in backfilling recently vacated positions when an individual advances in their career. This is critical whether the individual advances within the same employer or moves to a new employer.
    • Career advancement under a career pathways framework: Identification of state and national career pathways frameworks that VR counselors can use to guide service delivery, and incorporation of knowledge and resources on existing options such as apprenticeships.
    • Establishing a performance standard and indicators for “career advancement services”: In addition to basic service categories related to career advancement services, critical variables to measure performance around career advancement may include wages and number of hours worked, number of employer provided benefits (paid vacation, sick time, health insurance, retirement, and other benefits), SOC code, and level of education at the time of VR. These variables would be tracked at the time of VR application and closure to measure change over time.

  8. 1. Do State VR agencies need technical assistance or additional information from RSA related to on-demand training (e.g., online videos) for businesses and other employers related to disability issues?

    Yes, State VR agencies need this for two reasons: they need to know that they have a responsibility to be providing such training and information to businesses, and they need RSA support to be able to deliver the most impactful information in the most effective ways.

    2. If so, what topics should RSA specifically address related to on-demand training for businesses related to disability issues and through what mode(s) should RSA provide this technical assistance to State VR agencies?

    Topics to specifically address include tax credits and incentives for employers, customized employment, on-the-job training supports, disability awareness tools and resources, and non-traditional and accessible hiring practices. It would be best if RSA could provide this information in a mode that will enable State VR agencies to quickly begin getting the information out to employers. The information should be available to all staff of State VR agencies and RSA should encourage State VR agencies to ensure that all their staff are absorbing the information.

    3. Do State VR agencies need technical assistance or additional information from RSA related to the provision of career advancement services for individuals with disabilities who are employed?

    Yes, State VR agencies need to be provided with this information on a recurring basis so that they are equipped to provide these important services to individuals with disabilities.

    4. If so, what topics should RSA specifically address related to career advancement and through what mode(s) should RSA deliver this technical assistance to State VR agencies?

    State VR agencies need to know that entry level employment is not all that people with disabilities are capable of and that it isn’t appropriate to funnel every person being served by a State VR agency to entry level employment and then stop providing services when that goal is met. To this end, State VR agencies need to know how to make career advancement a priority through eligibility decisions and the inclusion of these services on IPEs. There should also be streamlined processes in place for individuals to turn to VR solely for assistance with career advancement.

  9. 1. From a broad-based perspective there are a number of alternative organizations that have videos available that provide well-developed on-demand training for employers (such as blueoceanbrain.org). With this in mind, resources may be better applied to initiatives such as “State as a model employer” to assist state governments and municipalities in hiring and managing individuals with disabilities.
    There are some specific topical areas that would be beneficial to have resources developed for and they are outlined in #2.
    2. Work Opportunities Tax Credit and other incentives
    Customized Employment from an Employers perspective
    Negotiating VR services in a Collective Bargaining environment
    Non-traditional and accessible hiring practices
    Innovative methods and models for business partnerships with VR and other government entities.
    3. Yes, career counseling tools that offer information on requirements and expectations within various industries.
    Technical assistance on defining, identifying and documenting “underemployment.” Also, TA for the development of procedures for “career advancement” in terms of both eligibility decisions and inclusion of services on IPE’s.
    TA on creation of streamlined processes for access and engagement for those who are looking for assistance with either career advancement or who are underemployed.

  10. 1.Do State VR agencies need technical assistance or additional information from RSA related to on-demand training (e.g., online videos) for businesses and other employers related to disability issues?
    Our agency has utilized our TA providers for many ongoing WIOA concerns: OOS, waitlist, Pre-ETS service delivery, collaborative funding models, etc. We have found that the TA and presenters are knowledgeable and experienced. Gotten some great feedback along the way. I think providing such information to employers and businesses in an easily digestible format is essential to our field.
    2.If so, what topics should RSA specifically address related to on-demand training for businesses related to disability issues and through what mode(s) should RSA provide this technical assistance to State VR agencies? Disability awareness, customized employment, how to meet the changing needs of employers and employees, and increase percentages of persons with disabilities in employment.
    3.Do State VR agencies need technical assistance or additional information from RSA related to the provision of career advancement services for individuals with disabilities who are employed? Our staff may request that, but we have a lot going on now.
    4.If so, what topics should RSA specifically address related to career advancement and through what mode(s) should RSA deliver this technical assistance to State VR agencies? Business engagement and career advancement as part of the overall employment and hiring practice.

  11. RSA feedback on employer services and career advancement under the VR program
    1. Do State VR agencies need technical assistance or additional information from RSA related to on-demand training (e.g., online videos) for businesses and other employers related to disability issues?
    Yes
    2. If so, what topics should RSA specifically address related to on-demand training for businesses related to disability issues and through what mode(s) should RSA provide this technical assistance to State VR agencies?
     Available tax credits and incentives
     On the job training support
     Wage reimbursement
     Disability awareness tools and resources
     On-site customized training and support

    3. Do State VR agencies need technical assistance or additional information from RSA related to the provision of career advancement services for individuals with disabilities who are employed?
    Yes
    4. If so, what topics should RSA specifically address related to career advancement and through what mode(s) should RSA deliver this technical assistance to State VR agencies?
    There is a significant need to provide training and resources on developing career pathways and workforce customized training that leads to a career ladder and/or enhanced employment. Using TPCA to establish innovative programs and services.
    Developing diversity talent pipelines to in-demand careers.
    Braiding and blending of workforce and VR funds to build responsive career training pathways.

  12. 1) Do State VR agencies need technical assistance or additional information from RSA related to on-demand training (e.g., online videos) for businesses and other employers related to disability issues?
    Yes
    2) If so, what topics should RSA specifically address related to on-demand training for businesses related to disability issues and through what mode(s) should RSA provide this technical assistance to State VR agencies?
    a) The alignment of Career Pathways and Apprenticeships and services to Businesses
    i) Web-based Training Web-based Training: brief, multiple, and segmented recorded training for practitioners; coaching strategies for supervisors based on the training for practitioners and recorded training on system strategies for executive leadership.
    ii) TA consultation
    b) Strategic alignment of Services to Business among the WIOA Core Parents (including TANF), the State entity responsible for home and community-based waiver Programs, Community Rehabilitator Providers and other stakeholders
    i) System Self-Assessment of current strategies (WINTAC Integration Continuum, SWOT, McKinsey 7 S, etc.)
    ii) Web-based Training: brief, multiple, and segmented recorded cross-training for partner practitioners; coaching strategies for supervisors based on the training for practitioners; and recorded training on system strategies for executive leadership.
    iii) TA – Facilitated planning with partners
    3) Do State VR agencies need technical assistance or additional information from RSA related to the provision of career advancement services for individuals with disabilities who are employed?

    Yes

    4) If so, what topics should RSA specifically address related to career advancement and through what mode(s) should RSA deliver this technical assistance to State VR agencies?
    a) Career Progression through Career Pathways
    i) Web-based Training: brief, multiple, and segmented recorded training for practitioners; coaching strategies for supervisors based on the training for practitioners; and recorded training on system strategies for executive leadership.
    ii) Cohort based TA consultation with individual State measurable outcomes and impacts
    b) Strategies for engaging customers with disabilities and business customers in planned career advancement
    i) Web-based overview of Best Practices
    ii) System Self-Assessment of current strategies (Adapted WINTAC Integration Continuum, SWOT, McKinsey 7 S, etc.)
    iii) Cohort based TA consultation with individual State measurable outcomes and impacts

  13. 1. Yes, specific information, ideas, examples, talking points to help VR staff address business specific topics like ADA, Affirmative Action, Federal Hiring, Disability Sensitivity topics.
    2. TA monies that would allow us to contract with local professional experts doing the work in the field. A train the trainer approach or direct messaging to VR staff and or business partners in consultation to provide value to our business partners on service delivery options. The value is the sharing of current professional expertise either through business professionals or post secondary educators who cover these topics on a routine basis.
    3. The concept of career advancement is understood.
    4. Technical assistance in the area of understanding Services to Employers and how to track that data to result in career advancement would be valuable. Improved understanding of performance measures for business services and data collected in regards to what constitutes a business service and how to track accurate data to help inform quality career advancement services. Current guidance is leaning towards broad definitions and DOL programming. Webinars or written guidance to provide clear expectations and strategies, ideas would be helpful.

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