Located in:
- Program-Specific Requirements for Vocational Rehabilitation (Combined or General)
The Vocational Rehabilitation (VR) Services Portion of the Unified or Combined State Plan [13] must include the following descriptions and estimates, as required by section 101(a) of the Rehabilitation Act of 1973, as amended by title IV of WIOA:
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[13] Sec. 102(b)(2)(D)(iii) of WIOA
- i. Comprehensive System of Personnel Development; Data System on Personnel and Personnel Development
Describe the designated State agency's procedures and activities to establish and maintain a comprehensive system of personnel development designed to ensure an adequate supply of qualified State rehabilitation professional and paraprofessional personnel for the designated State unit, including the following:
- 3. Personnel Standards
Describe the State agency's policies and procedures for the establishment and maintenance of personnel standards consistent with section 101(a)(7)(B) to ensure that designated State unit professional and paraprofessional personnel are adequately trained and prepared, including:
- 3. Personnel Standards
- i. Comprehensive System of Personnel Development; Data System on Personnel and Personnel Development
i. 3. A. Standards that are consistent with any national or State-approved or -recognized certification, licensing, registration, or other comparable requirements that apply to the profession or discipline in which such personnel are providing VR services; and
Current Narrative:
Colorado does not have state-approved or recognized certification, licensing or registration requirements for any of the personnel classifications used by DVR, specifically rehabilitation counselors. In collaboration with Colorado’s Department of Personnel and Administration, DVR has established minimum qualifications that require all counselors to possess an appropriate Master’s level degree, experience working with individuals with disabilities, and whenever possible, are eligible to obtain the appropriate nationally recognized certification. To date, DVR has not made changes to current personnel standards as a result of the Workforce Innovation and Opportunity Act, and all professional staff positions continue to identify minimum qualifications that meet or exceed legislated requirements. DVR works closely with the Department’s Office of Human Resources, to ensure the staff responsible for the initial screening of applicants is knowledgeable of the education and experience requirements needed to assure qualified personnel.
DVR is having increasing difficulty successfully recruiting and retaining fully qualified rehabilitation counselors. Currently, when circumstances prohibit DVR from hiring a fully qualified rehabilitation counselor, DVR often recruits at a rehabilitation counselor intern classification instead. At this time, when an individual is hired as a rehabilitation counselor intern, he or she is required to complete necessary coursework or accrue necessary employment experience to fully meet the minimum qualifications of a rehabilitation counselor within 5 years of the date of hire. In these situations, a training plan is developed with the individual identifying specific educational or experiential requirements that must be completed and the timeline for completion. DVR assists these staff to connect with universities offering financial assistance through RSA administered long-term training grants. DVR connects rehabilitation counselor interns with these funding sources to the extent possible, as DVR is unable to provide any financial support for staff to complete graduate coursework.While the rehabilitation counselor intern classification has proven to be a useful tool, particularly in rural areas of the state and to ensure a diverse workforce, it is proving to be an insufficient staffing solution in the current workforce climate.
DVR is actively exploring its current staffing plan, including minimum qualifications, job classifications, and position descriptions. The goal is to consider which rehabilitation counseling tasks are most critically performed by fully qualified rehabilitation counselors as compared to those tasks that do not require the level of specialized training held by DVR's rehabilitation counselors. DVR expects this project may result in more varied job classifications and a more collaborative team approach. As an example, DVR recently added a new position, a Pre-Employment Transition Services Technician, responsible for providing and coordinating pre-employment transition services to potentially eligible students with disabilities. These positions require a lower level of education (Bachelor’s Degree) than a rehabilitation counselor given they do not need to determine eligibility, develop plans for employment, or make case closure decisions.
For more specialized and harder to fill positions, agencies are able to request a waiver to recruit out of state. DVR does maintain a residency waiver for rehabilitation counselor vacancies to expand the recruitment pool beyond Colorado.
DVR ensures rehabilitation counselors predominately serving clients who are deaf are skilled in American Sign Language and knowledgeable of deaf culture. Evaluation of these skills is incorporated in the screening and hiring process for counselors working with this population. Similarly, orientation and mobility instructors and vision rehabilitation therapists must meet the same minimum qualifications of a rehabilitation counselor, along with specialized skills necessary to provide orientation and mobility services and vision rehabilitation.