Narrative: a. 2.

DVR Response to recommendation 1 

DVR agrees with the importance of ensuring the vocational rehabilitation program is accessible to individuals in all areas of the state from diverse backgrounds. Effective outreach continues to be a focus for DVR, as does ensuring sufficient staff and efficient processes so that outreach efforts can be paired with welcoming and engaging participation in the vocational rehabilitation program. Over the past several years DVR has strengthened communications, improved its website, and developed a social media presence. These efforts will continue as DVR has a staff position dedicated to Partnership Engagement and Communication. This staff leads DVR’s efforts to ensure effective communication and outreach strategies using a variety of modalities and approaches. DVR has identified strategies to a) expand partner relationships leading to co-enrollment and cross-program enrollments to ensure partners connect people with disabilities to DVR when appropriate, and b) engage in outreach and awareness campaigns to improve access to vocational rehabilitation services for unserved and underserved populations. Both of these strategies are seen as important steps in ensuring DVR reaches the individuals who can benefit from services. DVR also agrees that individuals with multiple barriers to employment may have even greater difficulty accessing DVR services. DVR Counselors work to improve access through strategies such as partnerships with Wraparound Coordinators, Drug Courts, Parole and Probation, and various other community organizations serving individuals with barriers to employment.    

Additionally, with COVID-19 as the impetus, DVR has created significant flexibilities in how services are provided. It is hoped that these flexibilities, including the opportunity to participate in services remotely, improves access for individuals who previously had difficulty engaging with DVR due to barriers such as transportation. 

DVR Response to recommendation 2 

DVR agrees and has identified priorities, goals, and strategies to support adequate staffing to meet the needs of people receiving services. In recent months, DVR has experienced increased difficulty in recruiting and retaining qualified staff, particularly rehabilitation counselors. As such, DVR has identified a strategy to develop a strategic and flexible staffing approach that will improve the customer experience. DVR must work within the staffing parameters that are identified through the state budgeting process and administrative rules. However, DVR is committed to exploring what flexibilities exist, explore innovative approaches, and consider how to improve services within existing FTE. 

DVR Response to recommendation 3 

DVR agrees that access to professional and ongoing training is critical to provide high quality services. All supervisors are responsible for ensuring Growth and Development goals are identified for each staff member during annual performance management planning. These Growth and Development goals can address professional development to support advancement, or may include inservice training to further develop an employee’s skills within their role. Goals are individualized to meet the training needs and goals of each individual employee. All employees also participate in regular Equity, Diversity, and Inclusion training, with additional training for supervisors, equipping them to support a culture of inclusion. DVR will continue to explore how to further promote and support a positive culture related to EDI, building a workplace and service culture that is welcoming and inclusive to all individuals, regardless of background.

DVR’s Professional Learning & Development unit develops curriculum and explores training resources for a variety of topics based on areas of training need that have been identified. DVR agrees that each of the the topics raised by the SRC warrant consideration by PLD throughout the period of the State Plan, in addition to topics such as WIOA Common Performance Measures, effective use of Labor Market Information, and the use of Work-Based Learning strategies to prepare individuals for competitive integrated employment.

DVR Response to recommendation 4 

DVR agrees access to high quality vendors is critical for DVR to meet the rehabilitation needs of recipients of VR services. DVR also agrees that gaps in capacity to provide employment support is particularly notable and there are increasing needs related to assistive technology. DVR also understands that reasonable reimbursement rates are essential to ensuring adequate capacity and high quality services. While DVR has a longstanding Fee Schedule committee and a staff position focused on vendor relations and maintaining the Fee Schedule this sole position has proven to be insufficient in the current climate of rapidly evolving business costs and changing services needs. DVR is exploring adding another full time staff resource to coordinate vendor development and evaluate vendor quality. DVRr has also become increasingly aware that inconsistent processes across offices has created unnecessary challenges for providers to work effectively with DVR. It is a priority of DVR to adapt processes, technologies, and disciplines that enhance relationships with vendors. DVR has a related strategy to develop vendors and improve the vendor relationship through consistent processes, evaluation of vendor quality and outcomes, and vendor training. 

DVR also agrees that there are a variety of sources of information that should be considered when determining appropriate rates of reimbursement for all services. It may be time to revisit methodology for determining rates and ensure that rates are commensurate with the skills, experience, and costs of providing services. The Rate Structure and Rate Methodology Student Report published by the Colorado Office of Employment First in December 2021, may be one source of information that DVR’s Fee Schedule Committee can use to evaluate and recommend rate increases. Other sources of information are likely relevant to ensure DVR supports a payment structure that incentives the right things, promoting positive outcomes and an exceptional service experience for people receiving services. 

DVR Response to recommendation 5 

DVR agrees that assistive technology (AT) is often a critical component to an individual’s employment success. Particularly, for DVR’s Blind and Low Vision Services (BLVS) unit, AT is an integral part of service delivery, with three AT instructors working directly with recipients of services to increase their use of AT. Vocational rehabilitation services are highly individualized and based on the unique barriers to employment that each individual experiences. DVR has begun collecting information about each individual’s access to and skill using both standard technologies and assistive technology. This information can help counselors assess what additional evaluation and training might be necessary. Access to timely AT evaluation, goods and services is an important part of the VR process for many individuals. However, specific technologies are at time determined in conjunction with a specific employment outcome and/or employment setting. DVR must also balance proactively providing assistive technology with the legal responsibility for partner agencies, schools, and employers to provide necessary accommodations to ensure compliance with the Americans with Disabilities Act.  AT can be an area in which staff report difficulty staying current with developing technologies and understanding the various options that might be available to those they work with.DVR’s Professional Learning & Development unit is exploring training options to increase staff knowledge and utilization of available AT services and goods. DVR is actively  exploring further collaboration with the Center for Inclusive Design & Engineering at University of Colorado  to expand training opportunities available to DVR staff. 

DVR acknowledges the need for qualified providers across the state to provide AT services and goods. DVR continues to evaluate and adjust the Fee Schedule related to AT evaluation and services with a goal to ensure established fees are not needlessly creating barriers to identifying a range of qualified providers. Further, general vendor development discussed in DVR’s response to recommendation 4 is expected to also support development of AT providers.

 DVR Response to recommendation 6 

DVR agrees that improving transition and pre-employment transition services is an ongoing effort. In 2018, DVR reorganized its reporting structure to better align all key functions related to the practice of vocational rehabilitation, including transition services. 

This structure has allowed for more efficient development and coordination of processes that support effective service delivery, including transition services, as addressed in Section (l).  In the fall of 2021, DVR added four new Pre-Employment Transition Service Technicians. These new positions will manage a caseload of potentially eligible students, including outreach, coordination and provision of pre-employment transition services, expanding DVR’s ability to provide and coordinate these services. DVR will monitor the effectiveness of these positions and expand to additional offices if appropriate.

DVR also agrees with the SRC that collaboration and stakeholder engagement is critical to moving the needle with more students having access to higher quality transition services. Adequate staff resources for education partners at the state and local level are essential to making forward progress. While it is unlikely DVR can directly impact the available staff resources at another State agency, engaged stakeholders may be able to effectively draw attention to the impact of limited staff resources on the effectiveness of efforts to improve transition services across Colorado. 

DVR Response to recommendation 7 

DVR appreciates the SRC’s interest and support in ensuring the ongoing availability of non-

Federal dollars necessary to access the full Federal allotment through the Rehabilitation Services Administration. DVR’s Executive Leadership Team has taken a proactive approach and identified various options to ensure sufficient non-Federal match is available to access the full Federal allotment and minimize any risk of Maintenance of Effort penalties. DVR will continue to provide the SRC and other relevant stakeholders, including the Colorado legislature, with updates and ensure there is an effective strategy in place to ensure consistent and secure funding for DVR. In recent years, DVR’s more pressing concern has been fully utilizing allotted funds, relinquishing $3.2 million for FFY19 back to RSA for reallotment to other states. DVR’s goal is to maintain strong internal controls and fiscal monitoring to ensure good stewardship of taxpayer dollars, maximizing Federal and non-Federal dollars to meet the vocational rehabilitation needs of Coloradans with disabilities. 

DVR Response to recommendation 8 . 

DVR agrees that continuing to develop understanding of the needs of the business community is necessary for DVR to achieve its mission. While DVR has had several staff dedicated to business outreach for a number of years, DVR’s Business Relations Unit has refocused its efforts to ensure DVR is able to establish and maintain effective strategic partnerships with the business community. Business Outreach Specialists take the lead in cultivating these relationships through outreach, education, and recruitment support.  A key goal and strategy is to better understand the needs of businesses in Colorado. 

DVR also recognizes the importance of effective use of labor market information when DVR counselors provide job exploration support and vocational guidance. Throughout 2020, DR focused on better use of LMI by counselors, leading to an increase in employment goals in key industries. These goals then led to increased employment outcomes and higher wages for individuals hired into these key industries. DVR has had particular benefit from using tools such as EMSI and plans to maintain this focus, providing ongoing staff support to further develop competence in this area for staff.

DVR’s Business Relations Unit has also placed particular focus on helping businesses to establish skills based hiring practices and will continue this work moving forward. THey’ve also developed a number of tools and quick guides to support inclusive hiring practice across both the public and private sector.

DVR Response to recommendation 9 

DVR agrees that it is critical that all individuals seeking services have equitable access to the services they need to achieve their employment outcome. While DVR has found there to be racial disparities in the amount spent on certain services, including training, further exploration is needed to understand what is leading to these disparities. DVR agrees that it would be helpful to better understand what is influencing these discrepancies and then consider what actions can be taken to improve equity. 

DVR continues to explore ways to best support a culture of EDI through training. All staff have completed a range of EDI training beginning in the fall of f2020 and continuing through 2021. In particular, all supervisors receive additional training to ensure they are facilitating and supporting EDI within their teams. DVR is open to considering whether a self-assessment for staff would contribute to increased self-awareness and foster culturally competent service delivery. While DVR agrees that it is important to attract and hire staff who represent the cultural diversity of Colorado, DVR’s Racial Equity Report demonstrated that DVR’s workforce is largely representative of those receiving services. Where groups are underrepresented within the workforce (i.e., individuals who are Hispanic/Latinx and those who are Black/African American), DVR does need to explore opportunities to recruit individuals from these backgrounds, and these recruitment efforts need to carry forward to hiring leaders and promoting staff into management positions. DVR agrees that it would be worthwhile to explore opportunities to increase diverse hiring, while working within the hiring parameters established through State Personnel Rules. DVR is also hopeful that piloting the Disability Hiring Preference within the Department of Labor and Employment will allow DVR to increase the staff with disabilities that it hires. 

DVR Response to recommendation 10

DVR agrees that stronger partnerships leading to increased referrals from partners such as WIOA programs, educators, and various community organizations is key to ensuring the right people hear about vocational rehabilitation. DVR is piloting an interagency agreement with Workforce Centers to restore Disability Program Navigators, which will have a key role in supporting referrals and co-enrollment between DVR and Workforce Centers. DVR has identified a strategy to further develop relationships at the state and local level to support co-enrollment and better connections for people with disabilities who may be served by other systems. DVR is also aware that it will be necessary to shore up some of the current staffing and business process challenges identified elsewhere to ensure that the work to develop these partnerships is met with appropriate, responsive, and effective services.