Narrative: a. 1.

The State Rehabilitation Council provides ongoing input and recommendations to VRS. The council’s annual reports, meeting minutes, and summary reports of public forums can be found online at: http://mn.gov/deed/job–seekers/disabilities/councils/rehab–council.jsp.

The SRC spent a substantial amount of time reviewing WIOA and preparing public comment. The council’s comments were previously submitted to RSA. In summary, the following recommendations were made:

1. RSA should closely monitor the impact of steering 15% of the federal appropriation to pre–employment services for transition aged youth. The SRC felt that this new mandate should have included new funding. This new mandate could have negative impact on services for adults.

2. The regulations should clarify how the common performance measures will be used. The regulations do not indicate if VR agencies will be compared to other VR agencies, or if VR will be compared to all programs funded by WIOA. If VR will be compared to all WIOA funded programs, common definitions need to be provided. For example, VR considers placement to be 90 days of successful employment while other programs consider placement to be one day of employment.

3. The SRC provided comment on the draft WIOA regulations related to Employer Training & Services. The primary concern is the language used in this regulation indicating that WIOA “authorizes the DSU to expend VR funds for training and services for employers [. . .].” The SRC is concerned that the language in this draft regulation is not strong enough to make this a priority for the DSU. There are many operational requirements that the DSU must fulfill, and if the draft regulations do not use language that do not require or allocate funding to this activity, it will not be a priority. SRC would like the language revised to emphasize the importance of this activity.

Additionally, of particular interest to the council is the type of services that should be available to employers. The MN SRC General proposes that the following training & services be available to employers: a. Disability Awareness Training b. Myths & Facts of ADA Accommodations Training c. VR Services 101 training for Employers. This training should discuss services and supports available to employees/employers including when and for how long after employee is hired supports can be provided through VR and Extended Employment (state funded long term supports).

4. SRC provided comment and suggestions on metrics that can assist in measuring “effectiveness in serving employers”. These measures could include: a. Repeat hiring of VRS referrals by employer b. Employer referrals of other employment businesses c. Post–placement career progression d. Number of individuals employed by each employer business partner e. Ratio of employers hiring VRS consumers &/or using Work Opportunity Tax Credits (WOTC) compared to all employers SRC noted that a measure that would be ineffective at measuring effectiveness in serving employers would be employee retention rates. This would not have the strongest correlation to the DSU effectiveness, as much of it is related to the employer’s own initiative and commitment.

5. The goal of competitive integrated employment that provides an opportunity for advancement is a very appropriate goal for the public Vocational Rehabilitation (VR) program. However, the Council is concerned that mandating the goal through regulation will infringe on the participant’s right to self–determination. People should be given choices and options for competitive integrated employment based on their abilities and capabilities. Establishing the appropriate level of integration for the person is best done on an individual basis through the counseling and guidance process, not federal regulations.

The employee with a disability may choose a competitive work site that is not fully integrated for a variety of reasons. The person may want or need a level of job coaching or other supports not available at a single site placement. The person may be introverted and not want a high level of interaction with co–workers. People may select a small work crew because they feel that working with people who have similar disabilities provides a supportive environment. Public transportation may not be available to single site placements, especially in rural areas.

The Council also has concerns about the requirement that individuals with disabilities employed by a community rehabilitation program (CRP) and working on a community–based service contract (i.e., working on a janitorial work crew) be integrated with co–workers without disabilities employed by the CRP instead of with co–workers employed at the community work site. Many people with disabilities choose employment on a work crew as a stepping stone to a competitive single site placement. The level of integration should be measured at the actual work site, not the CRP site, since the opportunity for advancement would be employment at the work site.

6. SRC recommends that each state have the discretion to define the ages of those potentially eligible for services. Due to limited resources, SRC recommends limiting pre–employment services to students on IEPs or Section 504 Plans who are age 16–21. Interested students with disabilities age 14 and older should have annual exposure to VR, including information and referral.

7. The term ‘hearing impaired’ is offensive and should be replaced with ‘deaf, hard of hearing and DeafBlind’.

Public Forums The State Rehabilitation Council convenes two public forums each year. The forums provide an opportunity to gather grassroots commentary and input regarding Minnesota’s Vocational Rehabilitation program, and they encourage participation in public conversation about matters of interest and importance in the arena of disability employment. May public forum: A Public forum on Employment and People with Disabilities in Southwest Minnesota.

The May forum examined local employment data for southwestern Minnesota, a predominantly rural area with limited resources. Key stakeholders providing input included County Case Management, Southwest Independent Living staff, VRS staff, and the Commission on Economic Development. Overall, the SRC was impressed with the VR staff and their creative approach to the challenges posed when providing services in a vast low population area.

Recommendations from the forum included: * Recognizing that VR staff in Greater Minnesota already collaborate with community resources, the SRC called upon VRS leadership to encourage VR staff to increase collaboration and provide creative leadership in such efforts. Specific examples included supporting the development of more work readiness programs, skill training, and student work opportunities. One participant noted that the nearest job coach was one and a half hours away. * The SRC advised that VR staff actively encourage homebased employment options. * SRC advised that VR continue to support early outreach and communication to potential VR consumers in hopes that early engagement will allow VR staff to build connections with employers and provide client choice. * The SRC advised that VR continue to support outreach to employers, including small businesses. VR has a unique and important role assuring small businesses are aware of ADA, on–the–job training, work opportunity tax credits, etc. * Lack of transportation impacted job choice, training opportunities and economic development. SRC recognized that transportation options are very limited in rural areas, but the problem cannot be ignored.

September public forum: Coordination between the Schools and Vocational Rehabilitation. The September forum was sponsored by SRC–General, SRC–Blind and the Department of Education. A panel discussed the federal and state initiatives designed to increase employability for students with disabilities, and how to maximize the positive impact of pre–employment transition services through effective collaboration.

Following a panel discussion of the current initiatives and a discussion of the current policies and practices around VR and school collaboration, participants broke into local teams consisting of the local school district staff, the VRS and SSB staff assigned to those school districts, and students with disabilities from the various school districts. Each team developed strategies on how to improve interagency coordination at the local level. Although not a part of the initial design, participants used the forum as an opportunity to network and become familiar with services available at other school districts and/or other agencies.

Review and analysis of consumer satisfaction The SRC expanded on the May forum by holding consumer discussion groups in five additional areas of the state. The Centers for Independent Living hosted these discussion groups, focusing on a subgroup of VRS participants who received both VR and IL services. Public discussions were held in Duluth (northeast), Fergus Falls (west central), Rochester (southeast) St. Cloud (central), and St. Paul (Twin cities metro).

Discussion topics were primarily focused on people’s experiences looking for and obtaining jobs, experiences working with placement services, experiences after getting the job and working for a while, and thoughts on the VR/IL collaborative. Following is a brief summary of the discussions:

Looking for and obtaining jobs: * Scheduling interviews can be difficult if you use door to door para–transit services. You need to schedule a week in advance and provide a specific address. If you submit multiple resumes you don’t know who will invite you to interview or on what date. * Several people mentioned VR was willing to fund school and coordinate academic accommodations. * Several people mentioned they had returned to VR on multiple occasions for placement assistance. One person mentioned he worked for 30 years as a professional, and then returned to VR when the job ended. Other people mentioned they wished they had known it was O.K. to return if the job ended or you were ready for advancement. * Most people were aware of assistive technology and many people accessed assistive technology services. One person mentioned that VR provided adaptations to her car to get to and from work, but no agency was available to modify the employer’s van that she uses while working.

Experiences working with placement services: * Overall, people were very positive about the practical help provided including job search, coordinating interviews, mock interviews, resume development, etc. Two people described their experience as awesome. Several people commented that job seeking was much more difficult than they imagined. They initially didn’t see the need for support, but very much appreciated it once they started the job search. * Several people felt they were being pushed to apply for available jobs in the local economy instead of VR developing jobs in their areas of interest. There was too much focus on the number of placements instead of the quality of the placement. One person mentioned that VR would not support his vocational goal because Labor Market Information indicated it was not in a growing industry. Another person mentioned that all he wanted was a d*** job; the process was too slow. * Some people indicated VR provided too many choices. It was too difficult to decide. This was more common with transition students entering employment for the first time.

Experiences after getting the job and working for a while: * There was recognition that the outreach, information and support VR provides to employers is unique and important. * The overall theme was that the VR process is important but can be frustrating at times. Participants generally felt that they would not have succeeded without VR support. * Several people felt 90 days of support after successful employment was not enough. Some people wanted more information on employee rights. Several people didn’t disclose their disability at hire and were uncertain if they should now disclose. Some people weren’t comfortable calling their counselor after case closure, or weren’t aware they could request additional services after closure.

Thoughts on the VR/IL collaborative: * The VR/IL collaborative was very important to the participants. One person stated that IL/VR was a “savior”. It helped her prioritize life’s major stressors. * Overall, people felt the collaborative was very helpful for prioritizing what needs to be addressed first, Social Security benefits counseling, learning about community services, independent living skills, and learning advocacy skills.

The SRC and VRS have reviewed the notes of the discussion groups to help determine staff training needs. More emphasis needs to be placed on teaching self–advocacy skills. Several people mentioned they would have benefited from specific services but never asked for the services. People were appreciative of the team approach (VRS staff, IL staff and CRP staff co–located) but some people presumed everyone was employed by VRS. It is important that everyone is aware that VR provides choice of vendor and you don’t need to select the co–located staff. VRS needs to look at better ways to disengage when the person is successfully employed and does not need long–term supports. The information about post–employment services needs to be more inviting.