1. Preparing for Your Disability Program ROCA Presented By: Laura Kuhn, Regional Disability Coordinator

2. Agenda  What is the Disability ROCA?  What Happens Prior to the ROCA?  Documents and Materials to Have Ready  Staff and Student Interviews  ROCA Scoring  Disability Program Requirements  Improving Your ROCA Score  The Brief-Out and ROCA Report  Be Prepared!  Resources 2

3. What is the Disability Program ROCA? 3

4.  Part of the Regional Office Center Assessment (ROCA)  Conducted every 1 to 2 years by a staff member (assessor) of the accommodation support contractor as part of the ROCA team  Program Assessment Guide (PAG) is used to conduct an overall assessment of your center’s Disability Program  Similar to accreditation assessments that occur at health facilities nationwide  Provides an opportunity to highlight strengths of your program (best practices) and to identify any concerns, challenges, or practices that may require change in accordance with the PRH 4

5. What Happens Prior to the ROCA? 5

6.  Center receives an introduction memo and Pre-ROCA questions from the assessor approximately 3 weeks prior to the visit  Introduction memo provides the dates of the assessment (typically 2 days), documents needed during the assessment and a request to arrange a staff/student interview schedule Quick Tips! Read your memo thoroughly – it provides everything you need to be well prepared Complete the Pre-ROCA questions prior to the assessment Review Policy 6

7. What Happens Prior to the ROCA?  Review all Disability-Related Policy!  PRH Chapter 1 1.4, R1-4 Appendix 107  PRH Chapter 2 2.2, R1 (b11), (d4) 2.2, R2  PRH Chapter 3 3.21, R2(g)  PRH Chapter 5 Exhibit 5-1 Exhibit 5-2 Exhibit 5-4  PRH Chapter 6 6.14 Appendix 605 Appendix 607 7

8. What Happens Prior to the ROCA?  The Disability Coordinator Desk Reference Guide and the Disability Coordinator Orientation on the Job Corps Disability Website are great places to review policies, procedures and obtain guidance for the Disability Program  Disability Coordinator Orientation webinars are offered quarterly 8

9. 9 Documents and Materials to Have Ready

10.  All requested documents and materials should be in one location and organized for the assessor  Provide a written list of all disability-related activities held on center including National Disability Employment Awareness Month, speakers, newsletters, webinars attended (certificates) 10

11. Documents and Materials to Have Ready STANDARD OPERATING PROCEDURES (SOPS):  Disability Coordinators’ Roles and Responsibilities  Applicant File Review Process  Reasonable Accommodation Process 11 Quick Tips! Use the sample SOPs on the Job Corps Disability Website

12. Documents and Materials to Have Ready APPLICANT FILE REVIEW:  Applicant File Review Log 12 Quick Tips! A sample file review log is available on the Job Corps Disability Website

13. Documents and Materials to Have Ready REASONABLE ACCOMMODATION:  Copies of Email notifications to staff regarding student accommodation plans  Accommodation files  Disability/no accommodation files  Career transition readiness materials/curriculum provided to students 13 Quick Tips! Staff emails should include all accommodation plans noting new and updated plans Career Transition materials are available on the Job Corps Disability Website

14. Documents and Materials to Have Ready INTRODUCTION TO CENTER LIFE:  Materials provided to new students (e.g., brochures, reasonable accommodation request form, copies of presentations)  Student handbook 14 Quick Tips! A brochure template is available on the Job Corps Disability website Sample Disability Program handbook language is available on the Job Corps Disability Website

15. Documents and Materials to Have Ready CIS REPORTS:  Recent monthly data review memos  Data Collection Report  Accommodation Plan with Notes Report  TABE Testing Accommodations Report 15 Quick Tips! Respond to monthly data reviews and get help from your Regional Disability Coordinator (RDIC) if unsure how to correct noted concerns prior to the ROCA Audit data collection and accommodation plans prior to the ROCA and on a regular basis.

16. Documents and Materials to Have Ready STAFF ACCESS REPORTS:  CIS3g staff access reports for all disability-related entry screens and reports  CIS authorization/staff access reports for disability data, reasonable accommodation plan, reasonable accommodation plan w/notes 16 Quick Tips! Reports are available from the center IT point of contact Check access prior to the ROCA and on a regular basis. A staff access graphic is available on the Job Corps Disability Website.

17. Documents and Materials to Have Ready PARTNERSHIPS:  Disability Partnership Tool REFERRAL PROCESS:  Referral/feedback forms used 17 Quick Tips! Include all partnerships that provide services to students with disabilities on your center/contacts made Sample referral forms are available on the Job Corps Disability Website

18. Documents and Materials to Have Ready READILY ACHIEVABLE BARRIER REMOVAL:  Americans with Disabilities Act (ADA) Checklist for Readily Achievable Barrier Removal  Center Accessibility Tool  Accessibility Plan with priorities and next steps based on the results of the ADA checklist and Center Accessibility Tool – meeting notes from annual updates 18 Quick Tips! Ensure all components of this process are completed including the updated 2011 ADA Checklist Provide meeting notes from annual updates

19. Documents and Materials to Have Ready TRAINING:  Documentation of annual Disability Program training for all staff  Documentation of new hire staff (within 90 days) Disability Program Orientation Training 19 Quick Tips! Provide staff sign-in sheets, topic and a copy of the materials presented/provided. If using SIMON for new hire staff training, provide copies of staff certificates.

20. Staff and Student Interviews 20

21. Staff and Student Interviews Individual Interviews  Assessors will ask for individual interviews with the following staff members:  Disability Coordinators (DCs) Health & Wellness Manager (if not a DC)  Academic Manager (if not a DC)  Career Transition Readiness Manager  Center Mental Health Consultant  Counseling Manager  Records Manager  TABE Administrator  Other staff members may be requested during the ROCA 21

22. Staff and Student Interviews Group Interviews/Individual Student Interviews  Assessors will ask for group interviews with the following staff members:  Group Interview 1: Academic, Career Technical and Career Preparation Period (CPP) instructors (at least one CPP instructor, 3 Academic and 3 Career Technical instructors)  Group Interview 2: Business Community Liaison (BCL), Center Standards Officer, Residential Manager, Work Based Learning Manager  On the first day of the ROCA, you will be provided with a list of students with accommodation plans whom the assessor will interview on the 2 nd day of the assessment 22

23. ROCA Scoring 23

24. ROCA Scoring  The PAG is used to score each of program requirement areas:  0/1 – Unsatisfactory - Critical requirements are missing – quality not achieved  2/3 – Marginal - Requirements and/or quality indicators are missing and quality assurance is minimal  4/5 – Satisfactory - Requirements and quality indicators are generally evident (requirements have been met)  6-7 – Very Good - Requirements are consistently met – innovative approaches are employed to promote continuous improvement  8/9 – Exceptional – Quality delivery of all requirements and achievement of quality indicators - Innovative approaches result in program enhancements and improved outcomes 24

25. Disability Program Requirements 25

26. Disability Program Requirements Disability Coordinator  Disability Coordinator [6.14, R1(a-b)]  The Health & Wellness Manager (or a health staff designee) and Academic Manager (or an academic staff designee) will function as DCs to oversee the program  Additional DCs may be appointed  Centers may choose to hire a full or part time DC to oversee the program rather than or in addition to appointing an academic and health DC  The roles and responsibilities of each DC will be defined in an SOP Quick Tips! Use the sample DC Responsibilities SOP on the Job Corps Disability Website to detail the roles of the DCs on your center 26

27. Disability Program Requirements Applicant File Review Process  Applicant File Review Process [6.14, R2(a-c); 1.4, R1-4; Appendix 107; Exhibit 5-1]  There is an applicant file review SOP that describes the applicant file process in detail  Applicant files should be processed in 30 days of receipt by the center Quick Tips! Use the sample File Review SOP on the Job Corps Disability Website to detail your applicant file review process 27

28. Disability Program Requirements Applicant File Review Process  The file review procedure (SOP) should contain:  Location where files are sent and logged in upon arrival to the center  The method of tracking the movement of the file to include an explanation of the center’s disposition of the file  Responsibilities and roles of applicant file review team members which include the Health & Wellness Manager, center clinicians, and the center’s DC(s)  Procedures for reviewing an applicant file to include acceptable reasons for recommending denial of an applicant  Procedures for reviewing and determining reasonable accommodation  Procedures for processing application withdrawals both before and after submitting a file for regional review  Timeframe the center establishes to complete the file review process to ensure it meets the PRH required timeframe of 30 calendar days  Storage, transmission and maintenance of the applicant file information (see Appendix 607) 28

29. Disability Program Requirements Applicant File Review Process The File Review Quick Quiz 1. The file review committee should only include the Health & Wellness Manager, center clinicians and DCs  TRUE! 2. The records manager is the file review coordinator  FALSE! 3. The only reason a file should be returned to Outreach and Admissions is 1) if the student withdraws or 2) the center cannot reach the applicant to conduct a clinical interview; and all supporting documentation of this is maintained with the file review log  TRUE! 4. An example applicant file review log is not located on the Job Corps Disability Website  FALSE! 5. You should start from scratch when writing your File Review SOP  FALSE! 29

30. Disability Program Requirements Reasonable Accommodation  Reasonable Accommodation Process [6.14, R3(a-c); Appendix 605; 3.21, R2G(g); Exhibit 5-1]  There is an SOP describing the reasonable accommodation process which includes all components outlined in Appendix 605 Quick Tips! Use the sample Reasonable Accommodation SOP on the Job Corps Disability Website to detail your reasonable accommodation process 30

31. Disability Program Requirements Reasonable Accommodation Reasonable Accommodation Committee (RAC) Quick Quiz 1. The following individuals should be members of the centers’ RAC: A. All departments that interact with students B. The HWM, center mental health consultant, center physician, dentist, TEAP and DCS only C. Only the DCs ANSWER: (A) – all departments that interact with students may at some time or another be needed to sit on your RAC meeting EXAMPLE: If you have a student with mobility issues, you may need the safety manager, food services, residential, recreation, etc. 31

32. Disability Program Requirements Reasonable Accommodation Requesting Accommodation Are requests being documented using the most current Reasonable Accommodation Request form located in Appendix 605? Are request forms being filled in and completed by the DC and applicant/student? Determination of Need Is the process between the center and applicant/student (and parent/guardian, when appropriate) to determine accommodation needs interactive? When there is documentation in the applicant’s file that a disability may exist is there documentation of an interactive process to determine the need for accommodation? Reasonable Accommodation Request Form - Program (or) Reasonable Accommodation Review Due to Documentation of Disability Form Ensuring Appropriate Documentation Does the documentation support the accommodations provided? If the Center Mental Health Consultant is doing testing/evaluations are assessments and procedures available for review? 32

33. Disability Program Requirements Reasonable Accommodation Reviewing the Request Do plans include technology that assists the student in becoming independent (e.g., books on tape, colored overlays, reading pens)? Are requests for accommodation handled in a timely manner? Are meetings/telephone contacts documented? Determining Reasonableness Do accommodations align with functional limitations? Is each request evaluated individually, and a determination made regarding whether it is reasonable? Are you aware that center’s cannot deny accommodations? Are you familiar with the accommodation denial process? Do you know how to request funding from the National Office for high cost accommodations when no other funding sources are available? Entering the Plan Are plans entered soon after a student arrives and before the first TABE test if TABE testing accommodations are provided? Are accommodation plans signed by the student and DC? Is a copy of the plan provided to students? Is there a copy of the signed plan in the accommodation file? 33

34. Disability Program Requirements Reasonable Accommodation Notification Are bi-weekly emails with a list of all students with accommodation plans sent to all staff who work directly with students? Does the email indicate students who new or updated plans? Do you maintain copies of these emails? Do managers ensure implementation of plans, how do they do that? Determining Accommodation Effectiveness Are accommodation effectiveness reviews done during the student’s 60-day ESP? Is student feedback documented? Is feedback from staff who provide accommodations documented? Documenting the Process Is the entire process documented from prior to entry until separation? Is this documentation entered in the CIS Notes Tab? 34

35. Disability Program Requirements Reasonable Accommodation Maintaining the Accommodation File Do accommodation files contain all required documents? Are you using a consistent layout for all files? Storing Documentation Have Disability/No Accommodation files been created and contain all required information? Are these files stored as a group in a separate drawer, file cabinet, or storage room that is locked? Is confidentiality and “need to know” enforced? Who has access to these files? Are these files sent to records when a student separates? Coordinating the Process Are the DCs coordinating the center’s reasonable accommodation process? 35

36. Disability Program Requirements Reasonable Accommodation Career Transition Readiness Are all students receiving information about workers’ rights and responsibilities including reasonable accommodation in the workplace? Quick Tips! See the Job Corps Disability website for ready-made transition materials and plans 36

37. Disability Program Requirements Reasonable Accommodation Available on the Job Corps Disability Website 37

38. Disability Program Requirements Introduction to Center Life  Introduction to Center Life [6.14, R4(a-c); 2.2, R1(b11); 2.2, R1(d4), R2]  The center provides new students with information about opportunities and benefits available in the center’s Disability Program  The center provides a variety of opportunities for new students to meet and interact with the DCs  The student handbook includes information about the Disability Program Quick Tips! A sample reasonable accommodation brochure is available on the Job Corps Disability Website Language for the handbook is available on the Job Corps Disability website – just copy and paste! 38

39. Disability Program Requirements CIS Disability Data and Accommodation Plans  CIS Disability Data Collection and Accommodation Plans [6.14, R4(a-f)]  A DC accurately enters the required data in the disability data collection and accommodation plans in CIS soon after the student enters the program  Data is entered prior to the administration of the first TABE test for students with TABE accommodations  Only the DCs will have access to the disability data collection entry screen, disability data report and the accommodation plan report with notes report in CIS  Only DCs or designee will have access to the accommodation plan entry screen  All center staff responsible for providing accommodations have access to the accommodation plan report in CIS  Accommodation plans do not contain any medical or diagnostic information 39

40. Disability Program Requirements Partnerships and Resources  Partnerships and Resources [6.14, R6(a-c)]  Center is developing disability-related resources and partnerships  The BCL staff and other appropriate staff are involved in this process  The center is documenting efforts to develop resources and partners by completing the Disability Partnership Tool or customized Disability Partnership Tool Quick Tips! The Disability Partnership Tool is available on the Job Corps Disability website or contact your RDIC to get your customized Partnership Tool The BCL may already have good contacts that can become partners and provide services to students with disabilities 40

41. Disability Program Requirements Referral Process  Referral Process [6.14, R7(a-b)]  A written referral/feedback system has been established to document the referral to the DCs  All referral forms are stored in students’ accommodation files, the Disability/no Accommodation file if the student has a disability, or in the student health record if no disability exists Quick Tips! A sample referral form is available on the Job Corps Disability Website Most centers place the form on the “S” drive Train center staff to use this – do not accept only phone calls or emails 41

42. Disability Program Requirements Readily Achievable Barrier Removal  Readily Achievable Barrier Removal [6.14, R8(a-e); Exhibit 5-2)]  The center has determined potential improvements to the physical accessibility by completing the ADA Checklist for Readily Achievable Barrier Removal  The center has determined potential improvements to the programmatic accessibility by completing the program Center Accessibility Tool  The center has developed an accessibility plan with priorities and next steps based on the results of the ADA Checklist for Readily Achievable Barrier Removal and Center Accessibility Tool  The accessibility plan is reviewed and updated annually (June 30 th )  The safety and facilities maintenance staff play a primary role in completing the plan with support from managers in all areas 42

43. Disability Program Requirements Readily Achievable Barrier Removal  Readily Achievable Barrier Removal [6.14, R8(a-e); Exhibit 5-2)]  www.adachecklist.org  Job Corps Disability Website Quick Tips! Tools to complete this requirement: ADA Checklist for Readily Achievable Barrier Removal Center Accessibility Tool Sample Accessibility Plan 43

44. Disability Program Requirements Readily Achievable Barrier Removal  Suggested Practices:  Assign safety and facilities staff to complete the Checklist for Readily Achievable Barrier Removal  Use a portion of the management team meeting to assign staff appropriate areas of the Center Accessibility Tool  Assign an administrative staff person to incorporate the findings from the checklist and tool into a plan, cut and paste using the sample plan  Use a portion of a management team meeting to review contents of plan, determine any actions that can be taken, and establish priorities and timelines  Use a portion of a June management team meeting to update the plan annually  Get students involved; for example, students in carpentry may complete sections of the ADA Checklist 44

45. Disability Program Requirements Readily Achievable Barrier Removal The Readily Achievable Barrier Removal Quick Quiz 1. If the center completed the ADA Checklist for Barrier Removal a few years ago, you don’t need to have it redone  FALSE! 2. The DC should send appropriate sections of the Center Accessibility Tool to corresponding staff members working in that particular area and request that they complete their section of the tool  TRUE! 3. Where can you find a sample Accessibility Plan?  On the Job Corps Disability Website of course! 45

46. Disability Program Requirements Staff Training  Staff Training [6.14, R9; Exhibit 5-4]  The center is providing annual all staff training on the Disability Program  The center is providing New Hire Staff Disability Program Orientation (first 90 days) Quick Tips! Secure copies of the sign-in sheets for annual training and sign-in sheets or copies of certificates for new hire staff training Training suggestions are available on the Job Corps Disability Website and disability orientation is available in SIMON, “Supporting Students with Disabilities in the Job Corps Program.” 46

47. Disability Program Requirements Quality Indicators  Quality Indicators  Q1 – Students are able to identify and access appropriate disability-related supports and/or services to meet individuals needs Quick Tips! Students with accommodation plans are familiar with DCs/Disability Program Students report they were contacted prior to arrival to discuss their accommodation needs Students know who to ask if they have a disability or accommodation concern The center assists students in obtaining GED/certification exam accommodations 47

48. Disability Program Requirements Quality Indicators  Quality Indicators  Q1 – Students are able to identify and access appropriate disability-related supports and/or services to meet individuals needs Quick Tips! There is a center-wide approach to providing accommodations (not just for academics) Students are signed up for Vocational Rehabilitation (VR), Centers for Independent Living or other supports Outside professionals/organizations were brought on center to speak with students about understanding accommodations in the workplace, community resources available to them, were provided with benefits counseling, etc. 48

49. Disability Program Requirements Quality Indicators  Quality Indicators  Q2 – Students are able to identify and access appropriate disability-related supports and/or services to meet individuals needs Quick Tips! Students with accommodation plans should know something about the Disability Program and who the DCs are Students report they were contacted prior to arrival to discuss their accommodation needs Students know who to ask if they have a disability/accommodation concern 49

50. Disability Program Requirements Quality Indicators  Quality Indicators  Q3 – Accommodation plans demonstrate employability readiness by featuring accommodations that foster student independence Quick Tips! Accommodation plans are not geared towards testing or just classroom accommodations Accommodation plans are provided to students with a variety of disabilities 50

51. Disability Program Requirements Quality Indicators  Quality Indicators  Q3 – Accommodation plans demonstrate employability readiness by featuring accommodations that foster student independence Quick Tips! Students with behavioral issues are provided behavioral plans and supports Accommodation plans include assistive technology (books on tape, colored overlays, or other assistive technology Students understand how accommodations relate to the work environment (WBL/Career Transition) 51

52. Disability Program Requirements Quality Indicators  Quality Indicators  Q4 – Staff is aware of Disability Program requirements and their individual role in supporting students with disabilities Quick Tips! Required SOPs are completed and approved by the region Staff know the DCs, their role and a basic understanding of the reasonable accommodation process Staff can name some accommodations and participate in accommodation effectiveness reviews DCs attend monthly DC calls and webinars on a regular basis 52

53. Disability Program Requirements Quality Indicators  Quality Indicators  Q4 – Staff is aware of Disability Program requirements and their individual role in supporting students with disabilities Quick Tips! Staff can articulate the written referral/feedback process All required staff training was completed and staff can recall some details of the training 53

54. Improving Your ROCA Score 54

55. Improving Your ROCA Score  Disability Coordinators  Center hires a full or part-time DC or has dedicated hours for the DC position  One or both DCs have a specialty (in VR, special education, mental health)  DCs are well know on center; staff know who to ask about disability-related issues or reasonable accommodation 55

56. Improving Your ROCA Score  Applicant File Review  Consider developing a locked folder on the share drive to improve communication throughout the process  Reasonable Accommodation  There is extensive monitoring and case management for students with accommodation plans  Career Transition Services provides students with a Career Planning and Transition Handbook. This handbook contains information on requesting reasonable accommodations for students with disabilities.  There are student-driven accommodation request forms offering an opportunity to discuss their disability 56

57. Improving Your ROCA Score  Introduction to Center Life  DC meets with each new student to explain the accommodation process and determine if the student would like to make a request  Have the disability brochure available in several areas around center  Put posters in several prominent areas around center that focus on individuals with disabilities – the Job Corps Disability Website has several free resources  CIS Disability Data Collection and Accommodation Plans  The CIS notes documents consistently documents the entire reasonable accommodation process including attempts to request accommodations for GED and certification exams  The Health & Wellness Manager maintains detailed outcomes data (e.g., academic and career technical gains, separation category, etc.) for students with disabilities. She then uses this data to compare outcomes for students with disabilities to those students without disabilities. She also looks at disability specific (e.g., learning disability, mental health disability) data to see if there are disabilities that may need more focus or are being served with increased frequency by the center. This data is used to guide staff training needs 57

58. Improving your ROCA Score 58

59. Improving Your ROCA Score  Partnerships and Resources  While all centers are required to have disability-related partnerships, this center goes above and beyond in the number of partnerships and the direct services students receive as a result of these partnerships  The center is a member of the City’s Disabilities Collaborative, a networking group of community organizations that helps build collaborative relationships to better serve people with disabilities. The DCs take turns attending the monthly meetings to network with potential disability partners and have expanded their disability partnerships as a result of this membership.  Secure services for students with disabilities while on center and when they leave, VR, Centers for Independent Living, etc.  The center has worked with the state assistive technology program to acquire adaptive equipment for a student 59

60. Improving Your ROCA Score  Readily Achievable Barrier Removal  The plan is updated yearly by a group of staff including the center director, maintenance supervisor, safety officer, manager of safety/security, finance and administration director, career development services system director, pathways manager, the social development director, and the disability coordinators  The facility maintenance and safety managers worked with the carpentry instructor to have students complete the ADA Checklist for Readily Achievable Barrier Removal. Students pasted pictures to the checklist to support their findings and suggest improvements. 60

61. Improving your ROCA Score  Staff Training  Provide more than the required annual staff training (monthly, quarterly, at Friday weekly meeting)  Train students how to advocate for their needs, understand community supports and the resources available to them for workplace accommodations, community resources, benefits counseling  Provide documentation of staff attendance from disability-related webinars  Include outside speakers 61

62. The Brief-Out and ROCA Report 62

63. The Brief-Out and Report  Upon completion of the assessment, the assessor will meet with DCs, management team and regional staff to provide an overview of positives and weaknesses from the assessment  A report will be provided to the regional office about 30 days after the review, the report is provided to the center director by the regional project manager (PM). Contact your PM if you do not receive the report.  Once reviewed, the center is asked to complete a Center Action Plan to address weaknesses and how the center plans on correcting these weaknesses 63 Quick Tips! If the center has questions regarding the weakness and how to respond, contact the RDIC for assistance

64. Be Prepared! 64

65. Be Prepared!  Send the interview schedule and Pre-ROCA questions to the assessor prior to the assessment  Have all documents and materials ready for assessment  Have a place set-up for the assessor to work  Have all interviews scheduled in the least amount of locations so the assessor can get to everyone and stay on schedule  DCs should plan to be available throughout the 2-day assessment for questions and assistance  Consider areas that technical assistance (TA) would be helpful – the quicker the assessment can completed, the more time the assessor will have to provide TA 65

66. Resources 66

67. Resources  Disability Coordinator Desk Reference Guide  Reasonable Accommodation Committee Guide  Job Corps Community Disability Website  Job Corps Community Event Registration – Webinars  Monthly Disability Coordinator Teleconference Call/Webinar  Regional Disability Coordinators:  Boston, Atlanta and Philadelphia Regions – Kristen Philbrook Kristen.philbrook@humanitas.com  Dallas Region – Laura Kuhn Laura.Kuhn@humanitas.com  Chicago and San Francisco Regions – Kim Jones Kim.jones@humanitas.com 67

68. Resources Job Corps Disability Website 68

69. Questions? 69