1. SRC Participation in Policy Development 1 NATIONAL STATE REHABILITATION COUNCIL FORUM JUNE 25, 2013

2. Today’s Presentation Review the SRC’s role in policy development, policy implementation and policy revisions Discuss how SRCs partner with State VR agencies in policy development 2

3. What is a Policy? “Policy” serves as a statement of intent used to implement a procedure or protocol. Policies guide how an agency provides services. Examples of VR policies… Applying for VR services Case closure Client confidentiality Customer financial participation Transition services 3

4. SRC Role in Policy 1. Mandate The SRC must… review, analyze, and advise VR agencies. (34 CFR 361.17(h)) 2. State Plan Assurances The designated state unit… regularly consults with the State Rehabilitation Council regarding the development, implementation and revision of state policies and procedures of general applicability pertaining to the provision of vocational rehabilitation services. (Assurance 4.2(b)(2)) 4

5. Policy Revisions Policy revisions occur for many reasons. For Example… 1. Inconsistent interpretations of existing written policies 2. The need for a written policy 3. Budget restraints requiring changes to services 4. Budget expansion allowing changes to services 5. Changes in federal or state legislation 6. Changes for clarity or readability 5

6. SRC in Action Mandate The SRC must…review, analyze, and advise VR agencies. 1. Identify members who have an interest or expertise in VR laws and regulations. 2. Establish a mechanism for the VR agency to routinely share with the SRC new or revised policies, and assessments of the potential impact of policy changes on employment outcomes. 3. Develop an ongoing partnership between the SRC and the VR agency that fosters dialogue and meaningful input. 6

7. SRC in Action State Plan Assurances The designated state unit… regularly consults with the SRC regarding the development, implementation and revision of state policies; consults with the Client Assistance Program (also a mandated member of the SRC); and consults with the director or a representative of Tribal organizations (including Native Americans or Hawaiian tribes) that are also mandated members of the SRC. 7 34 CFR 361.17(h); 34 CFR 361.20(c)(d)

8. SRC in Action Input from the SRC can also be beneficial in assessing the need to conduct a public meeting regarding policy change. Public Participation Prior to the adoption of any substantive policies or procedures governing the provision of VR services under the state plan, including making any substantive amendment to those policies and procedures, the DSA must conduct public meetings throughout the state, in accordance with the requirements of sec. 361.20. 8 34 CFR 361.10(d)

9. The State Plan CONSIDER… Among all stakeholders, only the SRC has its concerns, comments and suggestions included in the State Plan, including the requirement for a response in writing from the agency, and a review by RSA. 9

10. State Plan Attachment 4.2(c) 4.2(C) includes a summary of input provided by the SRC that includes: recommendations from the annual report of the council described in Section 105(c)(5) of the Rehabilitation Act and 34 CFR 361.17(h)(5); the review and analysis of consumer satisfaction described in Section 105(c)(4) of the Rehabilitation Act and 34 CFR 361.17(h)(4); other reports prepared by the council; and the response of the designated state unit to the input and recommendations, including explanations for rejecting any input or recommendation. 10 (Agencies that are independent commissions do not provide this attachment)

11. The SRC and Agency Partnership at Work SRC’s Role: Be a well informed partner Utilize all available resources to provide meaningful input Agency’s Role: Consult with the SRC on policy issues Provide meaningful information to foster open dialogue 11

12. SRC Panel Discussion How does your SRC work to ensure it is involved with the State VR agency in the development, implementation, and revision of policies and procedures? 12

13. SRC Panel Discussion What advice do you have for other SRCs that are working to strengthen the role and participation of the SRC with the state VR agency on policy issues? 13

14. Resources 36 th IRI The State Rehabilitation Council – Vocational Rehabilitation Partnership at: http://iriforum.org/books.aspx#36ua http://iriforum.org/books.aspx#36ua RSA website at http://www.rsa.ed.govhttp://www.rsa.ed.gov SRC On-line Training Series: http://www.erehab.org/SRC/http://www.erehab.org/SRC/ 14

15. Thank you! Melissa P. DiehlLisa A. Furber, Sr. Paralegal U.S. Department of Education Disabilities Laws Program Rehabilitation Services Administration Community Legal Aid Society, Inc. VR Program Unitefurber@declasi.org 202-245-6330 phone Melissa.diehl@ed.gov Bernadine Chavez Disability Rights New Mexico NM DVR SRC bchavez@drnm.org 15