Narrative: a. 1.

The SRC and CDOR partner together to carry out the Rehabilitation Act to maximize the employment and independence for individuals with disabilities. The ongoing collaboration between the SRC and CDOR on the VR Services Portion of the State Plan (State Plan) is an essential component and result of this partnership.

Over the past three years, the SRC and the CDOR Planning Unit have met numerous times to review, discuss and evaluate CDOR’s progress in meeting the 2016 – 2020 priorities: 1) services to youth and students with disabilities, 2) business engagement, 3) building program partnerships through capacity building, and 4) competitive integrated employment.

During this time, the SRC and CDOR Planning Unit also partnered on elements of the current Comprehensive Statewide Assessment and jointly developed and agreed to the 2020 – 2024 State Plan priorities and goals. The SRC enthusiastically supports, and acknowledges the quality and timeliness, of the two priorities and five goals within the 2020 – 2024 State Plan. The priorities of 1) increasing the quality and quantity of employment outcomes and 2) services to businesses demonstrates CDOR’s commitment to innovation and service delivery excellence.

As CDOR carries out these priorities and goals, the SRC encourages the CDOR to consider the following:

• The importance of stabilizing California’s VR workforce, particularly the recruitment and retention of CDOR’s VR Counselors. A sustainable and effective workforce will serve as the foundation for successfully carrying out and ultimately achieving the 2020 – 2024 State Plan priorities and goals.
• The significance of and need for cultural competency in the provision of VR services to youth, students and adults with disabilities. Per the 2017 Code of Professional Ethics For Rehabilitation Counselors, “The commitment involves providing respectful and timely communication, taking appropriate action when cultural diversity issues occur, and being accountable for the outcomes as they affect people of all races, ethnicities, genders, national origins, religions, sexual orientations, or other cultural group identities.”
• The need to support VR Counselors and staff with developing the skills and abilities to serve individuals with disabilities who have been involved with the criminal justice system. Employment is a critical component of reintegration especially for individuals with mental/behavioral health disabilities.
• The benefits of increasing the variety and supply of potential employers, including small businesses.
   

The 2019 SRC Annual Report (posted on CDOR’s website) provides additional details on the SRC’s perspectives and accomplishments, including efforts to modernize and improve the Consumer Satisfaction Survey.During the past term (October 2018 – September 2019) the SRC adopted four recommendations. These recommendations were the result of many productive and active discussions between the SRC, CDOR and other stakeholders, and reflect the SRC’s efforts to review, analyze and advise CDOR on the performance and effectiveness of California’s VR program. The recommendations are as follows:

SRC Recommendation 2018.6 – State Price Schedule

(adopted on November 15, 2018)

The SRC recommends the rebranding of individuals who receive CDOR services from consumer to students, job seekers or workers. This rebranding will strengthen CDOR’s business engagement and partnerships; align with WIOA and terminology used by businesses, industry and labor; convey CDOR’s expectations; and, empower those served by CDOR.

CDOR Response to SRC Recommendation 2018.5

The CDOR recognizes and appreciates the impact of language and terminology. In addition to the SRC’s perspective, CDOR is also interested in hearing feedback from the broader disability community regarding the modification of the term “consumer” and what impacts this would have. Prior to moving forward with such a significant change, conducting a policy and impact study (which could be informed by focus groups) would be critical. Based on the results of the study, CDOR would need to develop a communication and change management plan to ensure successful implementation. The CDOR welcomes the opportunity to collaborate and have further discussions with the SRC regarding this recommendation. The topic of terminology and re-branding is particularly timely as the SRC has been asked to provide feedback and insight at both the state and national levels in anticipation of the next reauthorization of the Rehabilitation Act.

SRC Recommendation 2018.6 – State Price Schedule

(adopted on November 15, 2018)

The SRC understands that efforts are taking place to cancel the State Price Schedule for Assistive Technology and replace it with an alternative purchasing mechanism that may have implications for students, job seekers and workers. The SRC recommends that CDOR provide the SRC with all policy documentation for review and feedback before implementation.

In the VR Services Portion of the Unified State Plan, CDOR assures that “The designated State unit regularly consults with the Council regarding the development, implementation, and revision of State policies and procedures of general applicability pertaining to the provision of vocational rehabilitation services” (34 CFR 361.16)

CDOR Response to Recommendation 2018.6

In January 2019, State of California agencies and departments transitioned from using the State Price Schedule for Assistive Technology (SPS-AT) to the new California Assistive Technology, Services and Devices (Cal-ATSD) Supplier Directory. The Cal-ATSD is a statewide change (not limited to vocational rehabilitation) that offers a streamlined supplier application, a user-friendly online directory, and expands the use of existing, flexible procurement methods available to all state buyers.

Due to the limited timeframe between issuance of the SRC’s recommendation and launch of the statewide Cal-ATSD on January 1^st, a comprehensive review by the full SRC of all policy documentation was not feasible; however, CDOR did actively update and engage the SRC in the months leading up to this statewide change. Opportunities included:

• On June 18, 2018, CDOR and the California Department of General Services (DGS) held a public forum to inform stakeholders (including the SRC and other advisory bodies) of efforts to reform the SPS-AT. 
• During the SRC’s August 15, 2018 and November 16, 2018 quarterly meetings, CDOR representatives provided an update on the SPS-AT, including stakeholder involvement, and offered an opportunity to address questions.
• Between September through December 2018, CDOR and DGS convened stakeholder focus groups to discuss issues and policy changes.
• CDOR representatives attended the SRC’s Executive Planning Committee meeting on December 19, 2018 and shared information regarding the policy changes. 

The CDOR commits to joining the SRC during the June 2019 SRC quarterly meeting to provide an update on Cal-ATSD, answer questions and engage in a collaborative discussion. Additionally, SRC members are welcome and encouraged to participate in stakeholder forums taking place now through December 2019 to support implementation and continuous improvement of the statewide Cal-ATSD. For details on how to participate, please contact your SRC Executive Officer. Aligned with our core values and mission, CDOR is committed to transparency and continually enhancing the Cal-ATSD to ensure an expeditious and effective procurement process for the State of California.

SRC Recommendation 2019.1 – Client Assistance Program Materials

(Adopted on June 13, 2019)

The SRC recommends that all local CDOR offices consistently and prominently display Client Assistance Program (CAP) materials in the reception areas. The Client Assistance Program will provide these materials free of charge to CDOR.

DOR Response to SRC Recommendation 2019.1

The Client Assistance Program is an excellent service available to support CDOR consumers. The SRC Executive Officer will coordinate with CAP and CDOR VR Employment Division representatives on next steps for distributing and displaying the materials. CDOR encourages CAP to also provide materials in alternative formats.

SRC Recommendation 2019.2 – Financial Participation 

(Adopted on June 13, 2019)

In light of CDOR’s funding challenges, the SRC appreciates the communication and partnership to identify cost mitigation strategies. As a result, the SRC supports CDOR’s proposed conceptual changes to the financial participation policy. The SRC would like to continue discussions with CDOR regarding resulting policy changes and impacts.

Additionally, the SRC appreciates CDOR’s thorough communication during the June 12 – 13, 2019 meeting (along with prior meetings) regarding funding changes and considerations, and that as a result, a potential challenge is that CDOR may not have sufficient funds to provide VR services to all individuals who apply. The SRC would like to remind CDOR of the following federal guidance: “There is no Federal requirement that the financial need of individuals be considered in the provision of vocational rehabilitation services” (34 CFR § 361.54) and encourages all CDOR team members to keep this guidance in mind during discussions with consumers.

July 22, 2019 Addendum: to provide clarify to the above statement, the SRC’s Executive Planning Committee offers the following addendum:

CDOR field staff should be reminded that an individual's case expenditures should not be discussed with consumers or be a consideration in the provision of goods and services.

CDOR Response to SRC Recommendation 2019.2

The SRC’s consideration, feedback and support of the proposed changes to CDOR’s financial participation policy is greatly appreciated. CDOR will keep the SRC involved as an active partner, particularly regarding policy changes that may impact consumers.

Per federal and state regulations, CDOR is required to provide information related to cost of services to assist an applicant or consumer with exercising informed choice. Additionally, CDOR is required to ensure that the Individualized Plan for Employment (IPE) is developed and implemented in a manner that provides the individual with the opportunity to exercise informed choice in selecting services, service providers, and methods for procuring services. The information is not used to persuade or influence a consumer, but rather is provided as part of the informed choice and the IPE development process. Regulatory language details the purpose and utilization of communication regarding cost and expenditures.     

For the regulatory language, please refer to the following sections of the California Code of Regulations. CDOR representatives are available to discuss and review this regulatory language with the SRC during a future meeting.

• § 7029.6. Informed Choice

• § 7130. Mandatory Procedures for Development of the Individualized Plan for Employment (IPE); Review; Amendment.