1. Pre-employment Transition Services (Pre-ETS)
Prepared for
Deaf-Blind Transition Task Force and Helen Keller National Center Representatives
January 22, 2018 1

2. Today’s Discussion
The role of the Pre-ETS topic area and the WINTAC with States.
An overview of Pre-employment Transition Services (Pre-ETS)
Q and A (questions from the group) 2

3. Workforce Innovation Technical Assistance Center (WINTAC)
Purpose
Provide training and technical assistance (TA) in five topic areas related to WIOA that will lead to effective implementation of the requirements of WIOA, including pre-employment transition services.
Goal is to assist State VR agencies and their partners to develop the skills and processes needed to meet the requirements of the Workforce Innovation and Opportunity Act (WIOA).
Implementation of effective and efficient pre-employment transition services for students with disabilities, as set forth in section 113 of the Rehabilitation Act.
Target audience is State Vocational Rehabilitation Agencies and related agencies
Rehabilitation professionals
Service providers 3

4. Workforce Innovation Technical Assistance Center (WINTAC)
Five Topic Areas:
Pre-employment Transition Services
Implementation of Section 511 Requirements
Resources and Strategies for Competitive Integrated Employment
Integration into the Workforce Development System
Transition to the Common Performance Accountability System 4

5. WINTAC Partners
The National Disability Institute and their LEAD Center
The George Washington University’s Center for Rehabilitation Counseling Research and Education
The University of Arkansas CURRENTS
PolicyWorks
The Career Index
The Council of State Administrators of Vocational Rehabilitation
Syracuse University’s Burton Blatt Institute 5

6. Pre-ETS Overview (Programmatic)
Pre-employment transition services are an early start at job exploration that:
Must be made available statewide to all students with disabilities who need them, regardless of whether a student has applied for VR services;
May begin once a student requests or is recommended for one or more pre-employment transition services, and documentation of the disability is provided to the VR agency;
Assist students with identifying career interests to be further explored through additional VR services, including transition services;
Must be provided or arranged in collaboration with LEAs; and
Are the only activities that can be paid for with the funds reserved under section 110(d)(1). 6

7. WINTAC Technical Assistance (TA)
Generalized or Universal TA
Targeted TA
Intensive TA
The WINTAC will provide technical assistance at three levels. The first level is universal general. The second is targeted or specialized. And the third is intensive or sustained technical assistance.
“Universal, general TA” means TA and information provided to independent users through their own initiative, resulting in minimal interaction with TA center staff and including one-time, invited or offered conference presentations by TA center staff. This category of TA also includes information or products, such as newsletters, guidebooks, or research syntheses, downloaded from the TA center's Web site by independent users. Brief communications by TA center staff with recipients, either by telephone or , are also considered universal, general TA.
“Targeted, specialized TA” means TA service based on needs common to multiple recipients and not extensively individualized. A relationship is established between the TA recipient and one or more TA center staff. This category of TA includes one-time, labor-intensive events, such as facilitating strategic planning or hosting regional or national conferences. It can also include episodic, less labor-intensive events that extend over a period of time, such as facilitating a series of conference calls on single or multiple topics that are designed around the needs of the recipients. Facilitating communities of practice can also be considered targeted, specialized TA.
Intensive, sustained TA” means TA services often provided on-site and requiring a stable, ongoing relationship between the TA center staff and the TA recipient. “TA services” are defined as a negotiated series of activities designed to reach a valued outcome. This category of TA should result in changes to policy, program, practice, or operations that support increased recipient capacity or improved outcomes at one or more systems levels. Intensive TA means that the TA provider and the State VR agency reach agreement (intensive TA agreement) on the goal of TA, define the goal in measurable outcomes, decide who is doing which activities to reach the goal, measure progress toward the desired outcome, and be able to define when the TA intervention has been successful.
Minimum Requirements: Implement 2 agreements first year, 7 second year, 7 third year, 7 fourth year.
We will provide intensive technical assistance to at least 23 state vocational rehabilitation agencies over the life of the project which is five years at a minimum. The WINTAC, however, will provide intensive TA to as many problems as we have resources for.
The WINTAC will engage in coordination activities that include establishing a community practice for each of the topic areas previously identified, and coordinating and collaborating with other relevant projects and technical assistance centers 7

8. Pre-ETS Intensive TA Activities
To ensure that the five required pre-employment transition services are made available statewide and provided for all students with disabilities who need them including those potentially eligible through community providers, education partners, contracting staff, or directly.
Work with VR to ensure that the agency has reserved and expended the minimum 15% of Federal funds on allowable expenditures for Pre-ETS.
Development of Policies and Procedures for Pre -ETS
Provision of training based upon the Pre-ETS activities and outputs completed above to ensure staff understanding of section 113 of the Act as amended by WIOA and the Agency’s updated policies and procedures.
Updating the SEA agreement to include section 113 and 511 8

9. Pre-Employment Transition Services TA - Examples
General or Universal TA: Information and resources on the WINTAC Website including toolkits, implementation checklist, guides, promising practices, FAQs
Targeted: TA on specific targeted topics for SVRAs and partners
Intensive TA: Comprehensive TA to assist the SVRA in effective and efficient pre-employment transition services for students with disabilities, as set forth in section 113 of WIOA. 9

10. Who May Receive Pre-ETS?
“Potentially eligible” as defined in 34 CFR361.48(a) means all students with disabilities who satisfy the definition in 34 CFR361.5(c)(51), regardless of whether they have applied, and been determined eligible, for the VR program.
A “student with a disability” is an individual who is in a secondary, post-secondary, or other recognized education program; and
Meets certain age requirements (varies from state to state); and
Is eligible for and receiving special education or related services under IDEA; or
Is an individual with a disability for purposes of section 504 of the Act.
A state may elect a lower age for the provision of pre-employment transition services - must be a State -not an agency- decision. If the State does not elect to provide pre-employment transition services at an earlier age, the IDEA minimum age range for the receipt of transition services would apply. Educational programs include: Secondary education programs; Non-traditional or alternative secondary education programs, including home schooling; Postsecondary education programs; and Other recognized educational programs, such as those offered through the juvenile justice system. Generally speaking, when considering whether or not the post-secondary program meets the definition of an educational setting, you will need to determine if that post-secondary training program offers educational programming that provides the individual with a recognized education credential, not just a certificate of attendance or completion of a program. 10

11. Pre-ETS Overview (Fiscal)
A State must reserve at least 15% of their Federal Award for pre-employment transition services (Section 110(d), and Section 113(a), §361.48(a)). When there are two State VR agencies, the reservation and expenditure of funds is a State matter that must be coordinated between the two agencies and resolved at the State level.
15% reserve may only be spent on pre-employment transition services (five “required”, nine additional “authorized” activities, and four “coordination” activities) for students with disabilities who are eligible or potentially eligible for VR services.
The “five required” activities under pre-employment transition services must be provided to students with disabilities. [Section 113(b) of the Act and §361.48(a)(2) and implementing regulations]
The “nine authorized” activities - may be provided if reserved funds remain after all required services have been made available to all students with disabilities who need them. [Section 113(c) of the Act and §361.48(a)(3) and implementing regulations]
The “four pre-employment transition coordination” activities - must be carried out, and reserve funds may be used to pay for pre-employment transition coordination activities. [Section 113(d) of the Act and §361.48(a)(3) and implementing regulations]
Reserve Requirement A State must reserve at least 15% of their Federal Award for pre-employment transition services (Section 110(d), and Section 113(a), §361.48(a)). 15% reserve may only be spent on pre-employment transition services (five “required”, nine additional “authorized” activities, and four “coordination” activities) for students with disabilities. The “required” activities under pre-employment transition services must be provided to students with disabilities. [Section 113(b) of the Act and §361.48(a)(2) and implementing regulations] “Authorized” activities - may be provided if reserved funds remain after all required services have been made available and provided to all students with disabilities who need them. [Section 113(c) of the Act and §361.48(a)(3) and implementing regulations] “Pre-employment transition coordination” - must carry out these activities and reserve funds may be used to pay for pre-employment transition coordination activities. [Section 113(d) of the Act and §361.48(a)(3) and implementing regulation]s 11

12. Five Required Activities
The five “required” pre-employment transition services activities which can be provided in group setting or individually, are:
Job exploration counseling;
Work-based learning experiences, which may include in-school or after school opportunities, or experience outside the traditional school setting (including internships), that is provided in an integrated environment to the maximum extent possible;
Counseling on opportunities for enrollment in comprehensive transition or post-secondary educational programs at institutions of higher education;
Workplace readiness training to develop social skills and independent living;
Instruction in self-advocacy, which may include peer mentoring.
These required activities may be provided in a group setting or individually.
Pre-employment transition services may be provided in “group settings under section 113 of the Act and §361.48(a) of the VR regulations – not under the “services to groups” authority under section 103(b)(7) and §361.49(a)(7).
The “services to groups” authority of section 103(b) of the Act and §361.49(a) of the VR regulations permits the provision of transition services in general, but not the provision of the more specific services identified as pre-employment transition services.
We can discuss examples of each of the required activities and individual vs group setting if they need additional information. 12

13. Job Exploration Counseling
Examples in a group setting
Information regarding in-demand industry sectors and occupations, as well as nontraditional employment;
Information about labor market composition;
Administration of vocational interest inventories; and
Identification of career pathways of interest to the students.
These required activities may be provided in a group setting or individually.
Pre-employment transition services may be provided in “group settings under section 113 of the Act and §361.48(a) of the VR regulations – not under the “services to groups” authority under section 103(b)(7) and §361.49(a)(7).
The “services to groups” authority of section 103(b) of the Act and §361.49(a) of the VR regulations permits the provision of transition services in general, but not the provision of the more specific services identified as pre-employment transition services.
We can discuss examples of each of the required activities and individual vs group setting if they need additional information. 13

14. Job Exploration Counseling
Examples of individual provision
Job exploration counseling provided on an individual basis might be provided in school or the community and could include discussions pertinent to the particular student about:
The student’s vocational interest inventory results;
In-demand occupations;
Career pathways; and
Local labor market information that applies to the student’s particular interests.
These required activities may be provided in a group setting or individually.
Pre-employment transition services may be provided in “group settings under section 113 of the Act and §361.48(a) of the VR regulations – not under the “services to groups” authority under section 103(b)(7) and §361.49(a)(7).
The “services to groups” authority of section 103(b) of the Act and §361.49(a) of the VR regulations permits the provision of transition services in general, but not the provision of the more specific services identified as pre-employment transition services.
We can discuss examples of each of the required activities and individual vs group setting if they need additional information. 14

15. Work-based Learning Experiences
Examples in a group setting
Coordinating a school-based program of job training and informational interviews to research employers;
Work-site tours to learn about necessary job skills;
Job shadowing; or
Mentoring opportunities in the community.
Work-based learning experiences, which may include in-school or after school opportunities, or experience outside the traditional school setting (including internships), that is provided in an integrated environment to the maximum extent possible; 15

16. Work-based Learning Experiences
Examples of individual provision
Work-based learning experiences on an individual basis could include paid or unpaid:
Internships;
Apprenticeships (not including pre-apprenticeships and Registered Apprenticeships);
Short-term employment;
Fellowships; or
On-the-job trainings located in the community.
If work-based learning experiences are paid, students with disabilities must be paid competitive wages to the same extent competitive wages are paid to students without disabilities in similar experiences. • Training stipends are permissible for students with disabilities participating in unpaid work-based learning experiences commensurate with and to the same extent that they are provided to students without disabilities participating in these experiences. • Discussion of the payment of wages and stipends for students participating in work-based learning experiences, is found in the preamble to the final VR regulations at 81FR 55629, (August 19, 2016).
Fee charged by the employer to provide the work-based learning experience. Examples may include the cost for: • The additional costs incurred by the employer for providing the work-based learning experience (e.g., printing of additional informational materials, •the purchase of additional uniforms for the students, or the installation of screen reading software (JAWS) on an employer’s computers (if needed by students who are blind or visually impaired and who are participating in the work-based learning experience offered by that employer); • The employer-provided staff or trainer who teaches the job tasks to the students; or • Other costs incurred by the employer in providing the work-based learning experience to the students, which are not individualized in nature. 16

17. Counseling on Opportunities in Post-Secondary Education
Examples for group setting
Course offerings;
Career options;
The types of academic and occupational training needed to succeed in the workplace; and
Postsecondary opportunities associated with career fields or pathways
Counseling on opportunities for enrollment in comprehensive transition or post-secondary educational programs at institutions of higher education; 17

18. Counseling on Opportunities in Post-Secondary Education
Examples of individual provision
Advising students and parents or representatives on academic curricula;
Providing information about college application and admissions processes;
Completing the Free Application for Federal Student Aid (FAFSA); and
Providing resources that may be used to support individual student success in education and training (i.e., disability support services) 18

19. Workplace Readiness Training
Examples of group services
Offered in a generalized manner in a classroom or other such group settings to provide programming to assist students with disabilities to develop social skills and independent living skills necessary to prepare for eventual employment.
These services could teach skills such as:
Communication and interpersonal skills;
Financial literacy;
Group orientation and mobility skills (i.e., to access workplace readiness training or to learn to travel independently);
Job-seeking skills; and
Understanding employer expectations for punctuality and performance, as well as other “soft” skills necessary for employment
Workplace readiness training to develop social skills and independent living; 19

20. Workplace Readiness Training
Examples of individual provision
All of the services discussed in the previous slide that may be provided in a group setting, may also be tailored to an individual’s needs in a work readiness training program, provided in an educational or community-based setting through instruction, as well as opportunities to acquire and apply knowledge. 20

21. Instruction in Self-Advocacy
Examples in a group setting
Generalized classroom lessons in which students: Learn about their rights and responsibilities; Learn how to request accommodations or services and supports; Communicate their thoughts, concerns, and needs, in order to prepare them for peer mentoring opportunities with individuals working in their area(s) of interest
Instruction in self-advocacy, which may include peer mentoring 21

22. Instruction in Self-Advocacy
Examples of individual provision
Conducting informational interviews; Mentoring with educational staff such as principals, nurses, teachers, or office staff; or Mentoring with individuals employed by or volunteering for employers, boards, associations, or organizations in integrated community settings; and Participating in youth leadership activities offered in educational or community settings. 22

23. Authorized Activities
If funds remain after all necessary “required” activities have been provided, VR may provide additional “authorized” activities that:
Improve the transition of students with disabilities from school to postsecondary education or an employment outcome; and
Support the arrangement or provision of the “required” activities.
“Authorized” activities (section 113(c) of the Act and §361.48(a)(3)) include, but are not limited to (there are nine authorized activities):
Providing instruction to VR counselors, school transition personnel, and other persons supporting students with disabilities;
Disseminating information about innovative, effective, and efficient approaches to achieve the goals of pre-employment transition services; and
Applying evidence-based findings to improve policy, procedure, practice, and the preparation of personnel, in order to better achieve the goals of pre-employment transition services.
The nine Authorized activities (section 113(c) of the Act and §361.48(a)(3)) of the VR regulations include:
Implementing effective strategies to increase the likelihood of independent living and inclusion in communities and competitive integrated employment;
Developing and improving strategies for individuals with intellectual disabilities and individuals with significant disabilities to live independently; participate in postsecondary education experiences; and obtain, advance in and retain competitive integrated employment;
Providing instruction to VR counselors, school transition personnel, and other persons supporting students with disabilities;
Disseminating information about innovative, effective, and efficient approaches to achieve the goals of pre-employment transition services;
Coordinating activities with transition services provided by LEAs under the IDEA;
Applying evidence-based findings to improve policy, procedure, practice, and the preparation of personnel, in order to better achieve the goals of pre-employment transition services;
Developing model transition demonstration projects;
Establishing or supporting multistate or regional partnerships involving States, LEAs, DSUs, developmental disability agencies, private businesses, or other participants to achieve pre-employment transition services goals; and
Disseminating information and strategies to improve the transition to postsecondary activities of individuals who are members or traditionally unserved and underserved populations. 23

24. Authorized Activities (Examples)
Annual on-line survey of and listening sessions with families of students in receipt of pre-employment transition services conducted to gather data and information and develop instruction, training, and professional service activities for PACER staff and vendors (other persons supporting students with disabilities);
Parent training workshops conducted by PACER for families of students who are blind, visually impaired, or deaf-blind, including topics such as self-advocacy, leveraging IDEA for effective transition planning and coordination of pre- employment transition services and developing independent living skills and soft skills necessary for employment; 24

25. Authorized Activities (Examples)
Outreach to and training materials (i.e., podcasts, videos and handouts) for families of students with disabilities, including accessible and family friendly resources, addressing topics such as building self-advocacy, working with vendors, and developing high expectations for students with disabilities in receipt of pre-employment transition services. Resources are to be provided through videos, podcasts and handouts.
Note: VR staff or PACER time to develop the materials and the costs incurred for printing the materials may be an “authorized” activity, clerical time or other “administrative costs” may not be paid with pre-ets reserve funds. 25

26. Authorized Activities (Examples)
Training for providers or vendors specific to maintaining high expectations for achievement of students with disabilities participating in pre-employment transition services, and understanding how to effectively partner with families of students with disabilities; and
VR and LEA staff training specific to special education services, advocating for students with disabilities within special education, and using the IEP to build self-advocacy skills in students with disabilities. This training could be provided in person or as a webinar. 26

27. Coordination Activities
These four coordination activities may be necessary for arranging and providing direct pre-employment transition services, and are therefore included under the implementation of pre-employment transition services in (a)(4).
Pre-employment transition coordination activities (section 113(d) of the Act and §361.48(a)(4)) are:
Attending IEP meetings, when invited;
Working with the local workforce development boards, one- stop centers, and employers to develop work opportunities for students with disabilities;
Working with schools to coordinate and ensure the provision of pre-employment transition services; and
Attending person-centered planning meetings for students with disabilities receiving services under title XIX of the Social Security Act, when invited. 27

28. Auxiliary Aids and Services
We encourage agencies to review the memo referenced on this slide for much more detailed guidance regarding the utilization of auxiliary aids and services for the provision of Pre-ETS services.
It is also important to note that this memo clarifies personal devices and services , which include individually prescribed devices, such as prescription eyeglasses or hearing aides, readers for personal use or study, or services of a personal nature, do not meet the definition of auxiliary aids and services under the ADA or 504 of the Rehabilitation Act and therefore, cannot be paid with the 15% reserve funds for Pre-ETS.
From Commissioner LaBreck: Auxiliary Aids and Services for Students with Disabilities in the Provision of Transition Services,
Auxiliary aids and services needed by a student with a disability to access or participate in pre-employment transition services would constitute allowable pre-employment transition services expenditures, and, therefore, may be paid with the funds reserved for that purpose.
Auxiliary aids and services ensure equal access to information, materials, services, and activities available to students with disabilities participating in pre-employment transition services.
The ADA’s title II implementing regulations define “auxiliary aids and services in 28 CFR (a complete listing is in the memo).
Examples include screen reading software programs to enable an individual who is blind to access information on a computer during a work-based learning experience. 28

29. Formal Interagency Agreement (MOU or SEA)
Agreement must include collaboration between VR and the State Education Agency for the provision of pre-employment transition services to students with disabilities. May include other entities such as state DD agencies, however only the state VR agency and the State Education Agency are mandated partners.
Purpose of the Agreement [Formal Interagency Agreement (361.22)]:
To facilitate and coordinate the smooth transition of students with disabilities from school to post-school activities, including the receipt of pre-employment transition services, transition services and other VR services.
To serve as a mechanism for VR agencies, State educational agencies (SEA) and, as appropriate, local educational agencies (LEA) to clearly specify the plans, policies and procedures for coordinating services to facilitate the transition of students.
To describe criteria for determining the financial and programmatic responsibilities that may include:
Purpose of the service;
Customary services; and
Eligibility for services. 29

30. Formal Interagency Agreement (MOU or SEA)
Purpose of the service: VR, SEA, and LEA personnel should discuss at the State level whether the purpose of the service is related to an employment outcome or education attainment, or if it is considered a special education or related service.
Customary service: Is the service one that the school customarily provides under IDEA part B?
Eligibility for services: Is the student with a disability eligible for transition services under IDEA?
Purpose of service: For example, Rehabilitation counseling that is necessary for the provision of FAPE should be provided by the school, whereas, rehabilitation counseling necessary for an employment outcome may be provided by the VR agency.
Customary Service: For example, if the school ordinarily provides job exploration counseling to its students, that does not mean that the school should cease providing the service simply because the service could also be provided as a pre-employment transition service under the Act by the VR agency.
Eligibility for services: For example: The population of students with disabilities served by the VR program is broader than that under IDEA because it includes students with disabilities under section 504 of the Act. As such, VR agencies may provide pre-employment transition services and group transition services to these students, whereas the schools may not do so under IDEA. 30

31. Coordination between VR and Education
Pre-employment transition services and transition services can be both vocational rehabilitation services under the VR program and special education or related services under IDEA.
VR and the LEA will need to agree upon the provision and payment for pre-employment transition services or transition services considered to be both a special education (or related service) or VR service.
Financial Responsibilities of VR Agencies and LEAs
LEAs are responsible for providing and paying for any transition service that is considered special education or related services necessary for ensuring a free appropriate public education (FAPE) as required under IDEA.
Nothing under title I of the Rehabilitation Act shall be construed as reducing a LEA’s obligation to provide the above-described services under IDEA (see section 101(c) of the Rehabilitation Act and §361.22(c) of the VR regulations).
Section 113 of the Rehabilitation Act, as amended by WIOA, requires VR to provide or arrange for the provision of pre-employment transition services in collaboration with local education agencies. Decisions as to who will be responsible for providing services that are both special education services and vocational rehabilitation services must be made at the State and/or local level as part of this collaborative process, and will be further defined in the formal interagency agreement. 31

32. Pre-ETS Programmatic Challenges
Educating Partners
Developing Capacities
Programmatic
Staff
Access to Students
Consent
Scheduling/Time
Determining what is a transition service under IDEA vs pre- employment transition service under WIOA (not duplicate or supplant services) 32

33. Pre-ETS Fiscal Challenges
Operating the VR program with the 15% reserve requirement.
Conducting the assessment of student needs for pre- employment transition services and fiscal forecasting before allocation of the remaining reserve toward authorized activities.
Developing the methodology, tracking, and reporting of the 15% reserve requirement.
Tracking and reporting fiscal information for potentially eligible students.
Determining allowable costs for the 15% reserve (administrative costs, specific services or activities, or when the service may need to be provided under a VR plan). 33

34. State Approaches (Fiscal)
Adjusting budgets
Assessing need for Order of Selection
Conducting the Comprehensive Statewide Needs Assessment (CSNA)
Assessing the need for fiscal forecasting to demonstrate funds remain for authorized activities
States using reserve funds for “coordinated” activities
States developing tools and mechanisms for tracking expenses. 34

35. State Approaches (Programmatic)
Collaborate with Education to Identify Students
Enhance Outreach Efforts and Student Access
Coordinate with Education to Develop Pre-ETS Services In school After school Summer
Contract with Providers/Vendors for Potentially Eligible
Partner with Employers and Others
Cross-Training 35

36. State Approaches (Access to Students)
Work with Education to:
Ensure a VRC is assigned to every high school
VRC maintains a consistent presence/set schedule
Provide introduction to pre-ets for students and parents
Embed VR and pre-ets into the beginning of the IEP process for access and consent
Develop local level process for the identification of students with disabilities
Identify how/what procedures will be followed to obtain necessary documentation 36

37. State Approaches (Outreach)
Collaborate with Education:
Parent nights
Back to school nights
IEP information
Career fairs
Participating in school events – booths or tables
VR Video 37

38. State Approaches (Partners)
Increased relationships with Community Rehabilitation Providers
Increased activities with Centers for Independent Living
Renewed and expanded relationships with state and local education agencies providing services under the Individuals with Disabilities Education Act (IDEA) and Section 504
Created partnerships with post-secondary educational institutions
Increased relationships with CRPs -VR working with providers to identify needs and gaps in services, RFPs to develop and expand pre-ets services in the five required activities, Providers working in schools delivering pre-ets, Providers collaborating with post secondary education programs, secondary ed, employers, and VR, to deliver pre-ets services.
Increased activities with Centers for Independent Living - Developing capacities in CILS to provide pre-ets services, Working with CILS to assist with the provision of support services for students to access pre-ets services , CILS working with CRPs to develop and provide pre-ets services
Renewed and expanded relationships with state and local education agencies providing services under the Individuals with Disabilities Education Act (IDEA) and Section Reviewing and amending interagency agreements to include provisions in section 113, 511, and Supported Employment for youth with disabilities; Developing and expanding programs; VR and Education partnering with other agencies, organizations, and programs
Partnerships with post-secondary educational institutions - Developing and expanding programs on campuses for students with disabilities; Multiple entry points; Multiple partners including workforce partners 38

39. State Approaches (Services)
After school job exploration counseling program
Use school personnel, employers, and other partners or providers jointly developing and providing pre-ets services
Hybrid programs
New or expanded programs and services provided by education for students under IDEA to include 504 39

40. Questions and Answers
1. What organizations participate in the MOU as called for under WIOA?
2. What types of technical assistance are provided to the organizations participating?
3. What types of obstacles are you experiencing in bringing partner programs to the table and breaking down silos?
The American Job Center network includes six core programs: title I Adult, Dislocated Worker, and Youth programs; the title II Adult Education and Family Literacy Act (AEFLA) program; the Wagner-Peyser Act Employment Service (ES) program, authorized under the Wagner-Peyser Act, as amended by title III of WIOA; and the Vocational Rehabilitation (VR) program, authorized under title I of the Rehabilitation Act of 1973, as amended by title IV of WIOA.
Core partners ONLY had to sign the State Combined Plan. The local plans have to include Core and Required partners.
§ What are the roles and responsibilities of the required one-stop partners?
Each required partner must:
(c) Enter into an MOU with the Local WDB relating to the operation of the one-stop delivery system that meets the requirements of § (b);
Agreements - There are several types of agreements that support effective partnership in WIOA implementation:
Agreements with Education Agencies
Tool Kit
Agreements with Local Workforce Development Boards
Contributors from the Departments of Labor, Health and Human Services, and Education provide us with "Sample MOU and Infrastructure Costs Tool Kit."
Examples of agreements from states used to support discussions facilitated by CSAVR, WINTAC staff have developed "The WDB MOU and Outline."
References from the Regulations important to the development of MOUs between Local WDB’s and Partner agencies are identified in "Guidance from WIOA in development."
An example of State Level guidance to facilitate WDB MOU development can be found in the New Jersey WIOA MOU Presentation.
Infrastructure Funding Agreements (IFA) and other Cost Sharing Agreements. The IFA is relevant to the physical center operation, and “other cost sharing” agreements are established to cover those other costs partner agencies agree are necessary to demonstrate their contributions to career and other services in American Job Center operation.
RSA TAC 17-03 provides guidance to SVRAs in establishing IFA and Other or Additional Cost Sharing Agreements with Local WDBs and Partner agencies
Related Regulations Regulations Related to IFA Agreements for IFAs and Other Cost Sharing Agreements
Resources on the GPS ION Site – A three-part webinar series (4/26/17 to 6/28/17) jointly presented by our Federal partner agencies
WIOA Wednesday - Memorandum of Understanding (MOU) Part I: Overview & Development
WIOA Wednesday - Memorandum of Understanding (MOU) Part II: Local vs. State Funding Mechanism
WIOA Wednesday - Infrastructure Part III: Wisconsin's Cost Database
Agreements with State Medicaid, DD, and Mental Health Agencies - Developed by Bobby Silverstein, in partnership with CSAVR and the LEAD Center
Model Cooperative Agreements Between VR Agency and Medicaid, Mental Health, and Intellectual and Developmental Disabilities Agencies
Agreements with American Indian Vocational Rehabilitation Services
State VR agencies are required to enter into a formal cooperative agreement with each American Indian Vocational Rehabilitation Services grant recipient in the State that receives funds from RSA. This language in the Rehab Act describes what is required for these agreements.
Data Sharing Agreements
This Toolkit was developed by WINTAC staff with input from RSA and through discussions with state representatives facilitated by CSAVR.
This joint guidance by the U.S. Departments of Labor and Education is a resource to provide information to assist State agencies (including Vocational Rehabilitation agencies and Workforce Development agencies), educational agencies and institutions, and service providers in performance reporting and evaluation requirements under the Workforce Innovation and Opportunity Act (WIOA).
Partnership Plus Agreements - State Vocational Rehabilitation Agencies can enhance the capacity of long-term supports for workers with disabilities through their partnership with Employment Networks participating in the Ticket to Work Program.
Ticket to Work FAQs
Abbreviated version
Partnership Plus and Ticket Assignment Chart
Ticket Payment Chart
Examples
Alaska
Iowa 40

41. Questions and Answers
1. Where does a school’s responsibility for Transition planning overlap with VR’s responsibility for preparing students for employment under WIOA?
2. Are there any examples of schools and VR working together meeting obligations under IDEA and WIOA?
3. How has section 511 of WIOA impacted students with more significant disabilities previously presumed to be on the path to sheltered employment or day activity? What career counseling is offered to those youth?
1. Where does a school’s responsibility for Transition planning overlap with VR’s responsibility for preparing students for employment under WIOA?
As stated earlier, this is very individualized, and will be determined at the local level depending on transition services currently offered at the local high school. However, there are three primary criteria offered as guidance: What is the purpose of the service; is this a service the school customarily provides under IDEA; and is the student eligible for transition services under IDEA. Primary criteria is Pre-employment transition services and transition services can be both vocational rehabilitation services under the VR program and special education or related services under IDEA. VR and the LEA will need to agree upon the provision and payment for pre-employment transition services or transition services considered to be both a special education (or related service) or VR service. Determined at local level depending on transition services offered at the local high school.
2. Are there any examples of schools and VR working together meeting obligations under IDEA and WIOA?
Yes. Many states working closely with education partners. Alaska and Missouri are listed on our Promising Practices page of website. Arkansas – Inclusion Film Camps is a great example of education and VR sharing resources for a new program.
New and Expanding Partnerships: JAG (Indiana, Nevada, LA), Title 1 Youth Partners (Alaska, MN, Texas), Juvenile Justice, Foster Care (Nevada), Education, Parent Networks (MN), CILS , Arkansas - Inclusion Film Camp (Joey Travolta) (State Examples - if states are in the room invite them to share more). Expanded partnerships with employers for work-based learning. Educators excited about providing employment experiences for students, and learning more ways to partner with VR and other entities in providing PreETS. CTE also now opening doors for students with disabilities to participate and gain skills.
Given limited staff capacity, VR reaching out to offer new contracts or RFPs to new and/or existing partners for assistance in providing work experiences and delivering pre-employment transition services to students with disabilities (schools -use Alaska example, community rehabilitation providers-can use Missouri summer work experience program as example or others, higher education/universities - use Missouri example).
3. How has section 511 of WIOA impacted students with more significant disabilities previously presumed to be on the path to sheltered employment or day activity? What career counseling is offered to those youth?
Still a little early to tell for sure, but post-secondary goals on IEPs more inclusive, these students are now being included in Pre-ETS activities, now getting referred to VR, more participation in work based learning, increased focus on financial literacy and benefits planning. VR offers career counseling in form of options for competitive employment and where to go to access those options. Before a youth with a disability can enter into subminimum wage employment, the youth must have received career counseling, and information and referral to Federal and State programs and other resources in the individual’s geographic area that offer employment-related services and supports designed to enable the individual to explore, discover, experience and attain competitive integrated employment.
The CC&I&R must be provided in a manner that facilitates informed choice and decision-making by the youth;
The information and referral services must not be for subminimum wage employment by a 14(c) entity and the employment-related services are not compensated at subminimum wage and do not result in work at a subminimum wage; 41

42. Questions and Answers
How can the deaf-blind network tap into national resources to support partners ?
● Employment
● Social Activity Engagement
● Community Engagement
● Higher Wages
Discuss the topic areas under competitive employment and the common performance measures. 42

43. Other Questions/Comments
Open Discussion 43

44. Pre-Employment Transition Services
Information and Resources on the Pre-ETS portion of the WINTAC Website
WINTAC Pre-ETS 44

45. Thank You
Melissa P. Diehl M.A. Ed. CRC Project Director WINTAC Pre-Employment Transition Services The George Washington University Center for Rehabilitation Counseling Research and Education (CRCRE) (410)
Christine Johnson, M.A., C.R.C. Senior Research Associate (513)
Brenda K. Simmons, M.S.
Senior Research Associate
(816) 45