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LEAD Center Reviews Unified WIOA State Plans: What We Learned

March 23, 2016

LEAD Center staff reviewed state plans from California, Iowa, and North Carolina utilizing a guide we developed that identifies key areas for plan design and implementation to advance effective and meaningful participation of youth and adults with disabilities in the workforce development system. LEAD Center staff analyzed both Title I and Title IV requirements with particular attention to new roles and responsibilities based on changes in the Workforce Innovation Opportunity Act.

Across all three plans, there is an expressed commitment to a) serve people across the spectrum of disabilities, including individuals with significant disabilities: b) cross-system collaboration where customers of the system are served by staff organized by function rather than program or funding source; c) program and physical accessibility with the new requirement of monitoring and review of American Job Centers annually based upon agreed state criteria defined by Section 188 of WIOA to promote universal access and equal opportunity; and d) Employment First and expanded VR partnerships with students with disabilities while they are still in high school with pre-employment transition services, a new WIOA requirement.

Several examples of promising strategies for greater inclusion and support of youth and adults with disabilities include:

  1. “Key features of the integrated service delivery model include integrated career center staffing, integrated customer pool, integrated customer flow, and integrated technology. Staff are organized by function, rather than by program or funding source” (North Carolina, p. 35).
  2. VR and Workforce Development System intercomponent staff training and technical assistant will promote equal, effective, and meaningful participation by individuals with disabilities receiving workforce development system services in all of the states’ Career Centers through the promotion of accessibility, the use of nondiscriminatory policies and procedures, the provision of reasonable accommodations, auxiliary aids and services, and rehabilitation technology for persons with disabilities” (North Carolina, p. 84).
  3. VR plans to increase transition service offerings to students with disabilities through partnerships with NC public schools. Areas of program development and service enhancement include:
    • “Summer internships for students/youth with disabilities;
    • Increased utilization of On-the-Job Training (OTJ) with students and youth;
    • Utilizing Transition Navigators to identify and serve students with disabilities who are potentially eligible and/or to provide VR PETS services to groups;
    • Increasing Project Search sites;
    • Hosting Self-Advocacy summer summits, camps, or school-based workshops;
    • Enhancing vocational evaluation tools and allocating increased vocational evaluation staff to serve students with disabilities in exploring career options; and
    • Increasing work-based experiences for students with disabilities who require on-the-job supports, such as job coaching, by partnering in innovative ways with community rehabilitation programs” (North Carolina, p. 107).
  4. “Most recently “North Carolina Department of Vocational Rehabilitation Services (NCDVRS) has partnered with the Division of Mental Health, Developmental Disabilities, and Substance Abuse Services (DMHDDSA) and the Division of Medical Assistance (DMA) on a workgroup through the Employment First Leadership State Mentoring Program with the mission of developing ways to infuse integrated employment into Medicaid Waivers and State Plan Medicaid Options. This is a national effort through the U.S. Department of Labor, Office of Disability Employment Policy (ODEP) to promote the alignment of policies, regulatory guidance, and reimbursement structures to commit to integrated employment as the priority option with respect to the use of publicly financed day and employment services to youth and adults with significant disabilities” (North Carolina, p. 264).
  5. “The criteria to solicit competitive proposals for the operation of Workforce Innovation and Opportunity Act of 2014 (WIOA) Title I, Public Law 113-128, will ensure that Youth Programs Local Areas’ youth program design must offer a unique opportunity to provide creative and innovative mix of services designed to address the academic, vocational, and employment needs of at-risk youth. Targeted activities include… financial literacy education” (North Carolina, p. 169).
  6. “Department of Rehabilitation (DOR) will designate a point of contact for and provide assistance and access to Local Boards for employers requesting assistance with Section 503 federal contracting hiring compliance” (California, p. 105).
  7. “DOR Will work with State Plan partners and Local Boards to develop competitive integrated employment opportunities, skill attainment strategies, and supportive services to assist individuals with disabilities, including those with intellectual or developmental disabilities” (California, p. 105). “DOR will provide disability expertise and technical assistance to the Local Boards, partners, and employers so as to facilitate the movement of individuals with developmental and intellectual disabilities into Competitive Integrative Employment” (California, p. 106).
  8. “WIOA describes the need for personnel to have a 21 century understanding of the evolving labor force and the needs of individuals with disabilities. CDOR’s existing requirement for VR Counselors to have a Master’s Degree in Rehabilitation Counseling supports this need. In addition, CDOR will offer the following training in 2016:
    • 21st Century Labor Market (Job-Driven Economy)
    • Competitive Integrated Employment
    • Customized Employment
    • Building Effective Partnerships with Employers
    • Building Effective Partnerships with Job Centers (One-Stop Centers)
    • Medical Aspects of Disability” (California, Appendix D, p. 40).
  9. “CDOR has entered into formal cooperative agreements with DHCS, the state agency responsible for administering the State Medicaid plan under title XIX of the Social Security Act (42 U.S.C. 1396 et seq.), and DDS, the state agency with primary responsibility for providing services and supports for individuals with intellectual disabilities and individuals with developmental disabilities. The cooperative agreements were developed with respect to the delivery of VR services for individuals with the most significant disabilities who have determined to be eligible for home and community-based services under a Medicaid waiver” (California, Appendix D, p. 22).
  10. “The state will employ and will require state plan partners to adopt or participate in (to the extent appropriate for each program), seven policy strategies that frame, align, and guide program coordination at the state, local, and regional levels. These policies (discussed in further detail in the section on strategies, tactics, and resources) will include the following:
    • Sector strategies: aligning workforce and education programs with leading and emergent industry sectors’ skills needs.
    • Career pathways: enabling of progressive skills development through education and training programs, using multiple entry and exit points, so that each level of skills development corresponds with a labor market payoff for those being trained or educated.
    • Regional partnerships: building partnerships between industry leaders, workforce professionals, education and training providers, and economic development leaders to develop workforce and education policies that support regional economic growth.
    • ‘Earn and learn’—using training and education best practices that combine applied learning opportunities with material compensation while facilitating skills development in the context of actual labor market participation.
    • Supportive services: providing ancillary services like childcare, transportation, and counseling to facilitate program completion by those enrolled in training and education courses.
    • Creating cross-system data capacity: using diagnostic labor market data to assess where to invest, and also, the use performance data to assess the value of those investments.
    • Integrated service delivery: braiding resources and coordinating services at the local level to meet client needs” (California, p. 10-11).
    “With over 38 million people, and about 12 percent of the nation’s population, California’s workforce and education systems are tasked with serving more people than any other state” (California, p. 43).
  11. 188 Disability Reference Guide created in partnership between the LEAD TA Center, the Civil Rights Center and DOL, ETA is being used as a foundation for system design in regard to ensuring ALL Iowans have equally and supported access services throughout Iowa. The One-Stop Operations and System Design Group is developing effective policies, plans and procedures that will be incorporated into the One-Stop Center operations” (Iowa, p. 123-124).
  12. “In developing the United State Plan, Iowa has incorporated several measures which will assist in ensuring that ALL Iowans have equal opportunities within the workforce delivery system and throughout the workforce. Iowa has worked very closely with and has relied upon the expertise provided by the Iowa Vocational Rehabilitation Services (IVRS). As a Core partner, IVRS has provided ongoing technical assistance and support regarding development of policies, procedures, and system design and evaluation protocols to ensure that ALL Iowans have full and welcoming access. Additionally, key IWD staff and WIOA work group implementers have participated in LEAD Center Webinars regarding serving persons with disabilities under WIOA and have infused the promising practices and policies throughout the vision and goals and the entirety of the Unified State Plan” (Iowa, p. 123).
  13. “The Disability and Employment Initiative through IWD/DOL has also been a key collaborator and partner in increasing employment outcomes. The DEI project has enhanced communication and awareness through their local projects with an Integrated Resource Team, financial literacy strategies and benefits planning” (Iowa, p. 258).
  14. “IVRS and the Iowa Department of Education are currently working on a shared data dashboard that will assist both IVRS and local high school districts to better understand the level of collaboration occurring between the two. This dashboard will outline the number of potentially eligible students on an Individual Employment Plan and compare that to the number of students who have been referred to IVRS. It will also outline outcome data such as students participating in post-secondary training, employment outcomes, hours worked, and hourly wages for students connected to IVRS. Also outlined on the dashboard will be Indicator 14 data collected by the Department of Education so that a comparison can be made between the outcomes of IVRS participants and those not connected to IVRS. This dashboard will help identify schools that are succeeding and schools that need improvement in their collaboration with IVRS. This will allow the two programs to target these schools for development of practices that will assist in successful outcomes for students with disabilities” (Iowa, p. 198).
  15. “Efforts to blend and braid funds, as well as establish uniform payment systems among state partners continues to be viewed as IVRS priority areas going forward” (Iowa, p. 240).

State Plan Links

Action Steps to be considered in your state include:

  1. Read and comment on your State Plan. Use the PowerPoints draft by the LEAD Center as a guide.
  2. Consider some of the identified promising strategies from North Carolina, Iowa, and California.
  3. Remember that all states are continuing to explore new expanded collaboration opportunities across state systems, strengthened relationships between VR and state and local education agencies to provide pre-employment transition services, and capacity building training for staff in American Job Centers to be responsive to the needs of job seekers with disabilities. Pay close attention to the mandate for program accessibility, defined as “policies, practices, and procedures providing effective and meaningful opportunity for persons with disabilities to participate in or benefit from aid, benefit, service and training” (29 CFR 38). Propose changes in structure, access to technology, other reasonable accommodations that can be made to customize career services and pathways for individuals with disabilities.
  4. Review the Notice of Proposed Rulemaking (NPRM) for Section 188 to learn more about state responsibilities to implement policies and monitor practices that afford equal opportunity and effective and meaningful participation of youth and adults with disabilities in the workforce development system.
  5. Review your State Plan to identify strategies that are being proposed to focus on financial literacy for youth and adults with and without disabilities. Section 129 (c)(2) includes financial literacy education as one of 15 elements that youth programs shall provide to support career readiness. Adult career services (Section 134 (c)(2)) include financial literacy as one of 11 specific services that should be provided if determined “to be appropriate in order for an individual to obtain or retain employment.”
  6. Please visit the LEAD Center webinar archives to gain a greater understanding of WIOA from a disability perspective.