Narrative: j. 2.

A. Consultation and technical assistance, which may be provided using alternative means for meeting participation (such as video conferences and conference calls), to assist educational agencies in planning for the transition of students with disabilities from school to post-school activities, including pre-employment transition services and other vocational rehabilitation services;   

DVR continues to monitor and implement the state-level agreement between DVR and CDE. This agreement promotes flexible and collaborative planning and service delivery among DVR, local education agencies, local school districts, and other state and community agencies for students ages 15-21 who are transitioning from school to work and/or post-school activities which lead to employment. The agreement promotes accessible, timely and uniform vocational rehabilitation services for all Colorado students who have a disability and require vocational rehabilitation services. Additionally, the agreement encourages education agencies to develop, implement and promote pre-ETS and career exploration for students with disabilities prior to their referral to DVR for services. The agreement defines how transition planning must occur to assure that vocational rehabilitation services complement the transition services provided by education agencies. Consistent with education requirements, transition planning must begin what the student is 15 years old, and local education agencies are expected to invite DVR representatives to the IEP meeting, with parent consent. The transition IEP coordinates the plans developed with other agencies, including DVR, to support effective transition. DVR's policy manual also stipulates the time of referral as occurring when the student's focus begins to shift toward employment. This allows the DVR Counselor to work closely with the eligible student, and their parent/guardian, to develop an Individualized Plan for Employment (IPE) before the student leaves the school setting (or if Colorado DVR is operating under an order of selection, before each eligible student able to be served under the order leaves the school setting). Finally, the agreement describes each party's commitment to providing transition services that lead to competitive integrated employment and documenting those services as required by CFR 397.30. However, legislation passed in 2021 that prohibits new individuals from entering subminimum wage employment as of July 1, 2021, so there are no longer any students seeking subminimum wage employment in Colorado. The key tenets of the agreement have been developed into a desktop guide, updated annually and entitled the “CDE/DVR Cooperative Services Handbook for Youth in Transition.” Thousands of these handbooks are distributed each year to youth, parents, educators, rehabilitation counselors and community-based agency providers.

Colorado has two interagency agreements with CDE. One is focused on supporting joint programming, pilots and other related activities. Programming examples include providing training, technical assistance, support and monitoring of the School to Work Alliance Program and the Program Improvement Process for Equity (PIPEline), which focuses on building environments where every student can realize their potential in high-wage, high-skill, in-demand career through Career Tech. Three years ago, DVR began a pilot in seven districts to bring benefits counseling and Discovery for students with most significant needs. This five-year pilot is coming to an end and will be evaluated for recommendations. Other related activities have highlighted cross systems training and Sequencing of Services.

A timeline has been established to complete Colorado’s second interagency agreement, (i.e., Cooperative Agreement) and its accompanying handbooks by October 1, 2024. One handbook, which focuses on information for education partners about assessment to create a more functional, responsive and accessible service delivery system is currently being updated by partners. The second handbook will serve as a “desktop” version to the Cooperative Agreement with examples that can be used as technical assistance for transition planning.

The Cooperative Agreement will incorporate WIOA, components related to the Student Data Transparency and Security Act (PDF) (HB 16-1423; C.R.S.22-16-101 et seq.), Employment First For Persons With Disabilities (SB 16-077), and the reauthorization of the Carl D. Perkins Career and Technical Education Act of 2006 (Perkins IV) now the Strengthening Career and Technical Education (CTE) for the 21st Century Act (Perkins V).  These editions will extend to DVR’s agreement with Institutions of Higher Education as well when this is updated. The purpose will be to educate partners on shared data and how it can be utilized in the design of effective service provision for strengthening post-secondary outcomes. Simultaneously, Colorado along with our education and CTE partners hope to create a Transition Cadre that includes agency representation of the WIOA state plan to develop a strategic plan to increase equitable access for all students with disabilities to Alternative Cooperative Education (ACE) while promoting increasing competitive integrated employment opportunities for persons with disabilities. Once complete, the interagency agreement will guide local interagency operating procedures.

DVR continues to partner with CDE to communicate with local education partners through regular Director's Meetings, newsletters and regional cadres. DVR has an ongoing and close partnership with leadership from CDE's Exceptional Student Services unit, ensuring the technical assistance needs of local teams are met. Staff from both agencies regularly meet to collaborate on how to best support educators, DVR Counselors, community partners, and families to meet the transition needs of students and youth with disabilities. This is particularly important as local teams experience staff changes, requiring ongoing training and technical assistance to support effective partnership at the local level. Local education partners may seek technical assistance and consult with DVR through various levels and methods of communication. At times, the local DVR Supervisor will consult with local education partners, such as when developing local practices for referral and DVR participation in IEP meetings. Other times, local partners will outreach to state level leadership within CDE and DVR to guide broader issues that arise in meeting and negotiating transition requirements of both systems.

DVR also collaborates with educators to reach out to and identify students with disabilities who might benefit from vocational rehabilitation services. Meeting these needs remains a challenge, particularly within the rural and mountainous areas of Colorado, as well as for students who have the most significant disabilities. The use of technology has helped to increase collaboration within large rural geographic areas, but could be utilized more. Those areas utilizing technology have been able to conduct one-on-one meetings with students and Pre-ETS workshops, including career preparation, connecting activities, youth development and leadership. Additionally, DVR staff have the capacity to video chat when feasible. This is successfully and widely used with young adults and the agencies and families who support them. DVR’s Youth Services and Transition Unit is using technology, including Zoom to provide technical assistance, support and training to education and DVR partners simultaneously on topics that support partners as they strive to meet the ever growing need of Colorado’s youth with disabilities who are preparing for career entry.

DVR intends to further explore social media and other electronic means of communication to attract youth, and as a mechanism to deliver Pre-ETS to students with disabilities. Using this technology is intended to improve individual engagement and rapport with youth and DVR continues to pursue options such as Podcasts to reach more students. 

Colorado recognizes a need to refine the delivery of Pre-ETS and is exploring with education partners how to best provide students with Pre-ETS that are intentional in order to make a positive contribution to the IEP outcome.  DVR is also beginning to analyze available data with an eye toward identifying gaps and developing staff training to improve service delivery. 

B. Transition planning by personnel of the designated State agency and educational agency personnel for students with disabilities that facilitates the development and implementation of their individualized education programs (IEPs) under section 614(d) of the Individuals with Disabilities Education Act; 

The interagency agreement specifies how DVR and local education agencies will collaborate to implement each individualized education program, including facilitating the linkage of IEPs to other individualized service plans ensuring there are no gaps in services as the students leave school. Currently, DVR is invited and participates in IEP meetings inconsistently. However, DVR is routinely able to access student IEPs with authorization from the student's parent or guardian. This allows DVR to coordinate and align pre-ETS and vocational rehabilitation services with goals and services identified on the student's IEP. As DVR and CDE update the interagency agreement, opportunities to improve practices and procedures that will facilitate joint planning and provision of services to students with disabilities will be explored. 

C. The roles and responsibilities, including financial responsibilities, of each agency, including provisions for determining State lead agencies and qualified personnel responsible for transition services and pre-employment transition services;  

The interagency agreement includes roles and responsibilities of each party. The agreement references each party's mandated transition responsibilities and outlines services and activities that each may have primary or shared responsibility to provide. This information is consolidated into a Collaborative Services Chart, which is summarized in the “CDE/DVR Cooperative Services Handbook for Youth in Transition”, which is broadly distributed annually to each partner and families of students with disabilities. The most recent agreement has been expanded to include Pre-ETS.

Additionally, the agreement clarifies that education is responsible for providing and funding equipment and services needed for a student to participate in secondary education. Goods or services that are needed for the student to achieve their employment outcome may be provided as a vocational rehabilitation service toan eligible individual. The agreement requires that both education and DVR clearly stipulate these responsibilities and agreements in both the IEP and the IPE. 

D. Procedures for outreach to and identification of students with disabilities who need transition services and pre-employment transition services. Outreach to these students should occur as early as possible during the transition planning process and must include, at a minimum, a description of the purpose of the vocational rehabilitation program, eligibility requirements, application procedures, and scope of services that may be provided to eligible individuals; 

Through collaboration with education officials, DVR provides consultation and technical assistance to assist educators, as early as possible in the transition process, in the planning and provision of services that facilitate the movement of students with disabilities from school to post-school activities. Outreach occurs in a variety of ways and can vary to meet the local needs and include DVR staff participating in Transition Fairs/Resource Nights sponsored by a local district; DVR presence at various parent and stakeholder events targeting families with transition age students; outreach through partner agencies serving youth and students with disabilities, etc. Additionally, the youth services unit has developed new marketing materials to aid VR staff with sharing necessary information with educators, students, and their families. These materials include an updated website with specific information for students, families, educators and services providers, a new rack card with clear and concise information on services available and a youth services video, featuring youth that have been served by DVR, that shares information about the entire VR process for students and youth with disabilities.

Maintaining effective partnerships at the local level continues to be an ongoing effort. Time is dedicated to mediating these relationships due to staff turnover within both entities, lost connections, and frustration with DVR processes. Unfortunately, this has required training to be more reactive in response to immediate requests, rather than proactively addressing upcoming needs. However, training continues to be a priority as DVR and CDE work with local teams to identify promising practices that can be replicated statewide to promote effective Pre-ETS and transition services.  As Pre-ETS were introduced and new programming was developed, other with school districts as the service provider, additional training needs with education partners were discovered, such as invoicing and reporting of services.

Consideration is being given to utilizing the Transition Cadre to develop statewide training with consistent messaging that can be made available to ease the sequencing of services as students are linked to adult systems. DVR’s Youth and Transition Services unit is in the process of adding two new positions to provide technical assistance and support in implementing transition services across the state, as well as the ongoing monitoring of youth services related contracts. These additional staff resources will increase DVR’s ability to engage in strategic planning and more intentional program development to enhance WIOA implementation in Colorado and promote active participation of various stakeholder groups to better coordinate efforts. All with the goal of streamlining services to avoid duplication and truly creating pathways that result in positive post-school outcomes for students with disabilities.

DVR plays an integral role in annual institutes facilitated by CDE for local secondary education teams. The intent of DVR’s involvement with the institutes is to elevate awareness and expand DVR’s presence within education. The purpose of the institutes is to improve the quality of services in the area of secondary special education and transition at the local level through knowledge, capacity building, dissemination and outreach. The institutes, and the action plans which result from them, are supported and overseen by the National Technical Assistance Center on Transition: The Collaborative (NTACT:C). Institute efforts focus on improving State Performance Plan Indicator outcomes identified in IDEA. Each of these Indicators measures the state education agency's effectiveness in meeting the needs of students with disabilities. For example, Indicator 13 measures the percentage of students with appropriate post-secondary goals on their transition IEP, and Indicator 14 measures post-school outcomes for students who had an IEP when they left school. DVR commits content experts, presenters, DVR counselors, and technical assistance to local institute teams. This group is dedicated to identifying ways in which we can make positive changes for students.

Colorado’s Transition Community of Practice gave way to a new group, the Cross Agency Collaborative on Transition. Key initiatives and expertise explored by this group include WIOA implementation, apprenticeship expansion, business services, job seeker services, career and technical education, career pathways, talent pipeline development, sector partnerships, special education, individual career and academy plans, incentive funds for industry recognized credentials and more. Over the last year, this group has been identifying a united direction using each entities’ key initiatives. The group has also identified additional parties to include, such as subject matter experts in behavioral health and I/DD.  Invitations will be extended to these groups for their contribution to align goals which support improved post-secondary outcomes.

The DVR youth services team has started a Family Member Taskforce to better identify the needs of family members that support students and youth with disabilities we serve. This taskforce meets quarterly to provide important feedback and guidance about marketing and communication to youth and families, the VR process and ideas for improving the quality of services for students and youth with disabilities.

DVR is also moving forward to create several outreach tools which will be utilized with both parents and representatives, including a family friendly brochure and restructuring DVR’s website with links for parents and representatives with information and resources specific to transition. Using NTACT materials and developing consistent messaging with partners, such as the Cross Agency Collaborative on Transition, has also been an important strategy to improve outreach. Improving parent training and outreach is also a high-level priority and has been built into our state plan with CDE at NTACT and includes our parent education center, PEAK. 

E. Coordination necessary to satisfy documentation requirements set forth in 34 CFR part 397 regarding students and youth with disabilities who are seeking subminimum wage employment; and 

Colorado DVR maintains policy to meet all requirements set forth in 34 CFR part 397 and has ensured that students interested in subminimum wage receive the required services and documentation. However, in 2021, Colorado’s legislation passed a law phasing out subminimum wage employment over the course of five years. Beginning July 1, 2021, no new subminimum wage employment could begin, essentially eliminating subminimum wage for the population for whom these requirements apply. As of the summer of 2023, no youth or adults with disabilities are employed earning subminimum wage. 

F. Assurance that, in accordance with 34 CFR 397.31, neither the SEA nor the local educational agency will enter into a contract or other arrangement with an entity, as defined in 34 CFR 397.5(d), for the purpose of operating a program under which youth with a disability is engaged in work compensated at a subminimum wage.

Subminimum wage is currently prohibited by law in Colorado for all youth and adults with disabilities, therefore neither the SEA or local education agencies can enter into contracts in which youth with disabilities engage in work compensated at subminimum wage.