Located in:
- Program-Specific Requirements for State Vocational Rehabilitation (Combined or General)
The Vocational Rehabilitation (VR) Services Portion of the Unified or Combined State Plan must include the following descriptions and estimates, as required by sections 101(a) and 606 of the Rehabilitation Act of 1973, as amended by title IV of WIOA.
- i. Comprehensive System of Personnel Development.
In accordance with the requirements in Section 101(a)(7) of the Rehabilitation Act, the VR agency must develop and maintain annually a description (consistent with the purposes of the Rehabilitation Act) of the VR agency’s comprehensive system of personnel development, which shall include a description of the procedures and activities the State VR agency will undertake to ensure it has an adequate supply of qualified State rehabilitation professionals and paraprofessionals that provides the following:
- i. Comprehensive System of Personnel Development.
i. 3. 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
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
B. The establishment and maintenance of education and experience requirements, in accordance with section 101(a)(7)(B)(ii) of the Rehabilitation Act, to ensure that the personnel have a 21st century understanding of the evolving labor force and the needs of individuals with disabilities.
Current Narrative:
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
Colorado does not have state-approved or recognized certification, licensing, or registration requirements for any of the personnel classifications used by DVR, and 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. At this time, when an individual is hired as a rehabilitation counselor intern, they are 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 to ensure a diverse workforce, it is proving to be an insufficient staffing solution in the current workforce climate.
DVR has actively explored its current staffing plan, including minimum qualifications, job classifications, and position descriptions. The goal was 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. In May 2022, DVR implemented a Strategic Staffing model that incorporates an interdisciplinary team approach to providing services. Currently, this model is implemented in at least one of DVR’s field offices per region. This included implementing a new position, the Initial Engagement and Eligibility Technician. This model has resulted in the last year to increase engagement and rapport between persons we serve and DVR staff, build trust within DVR teams, and decrease the amount of time from application to an Individualized Plan for Employment within offices that participated. This project has resulted in more varied job classifications and a more collaborative team approach.
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 persons we serve 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.
B. The establishment and maintenance of education and experience requirements, in accordance with section 101(a)(7)(B)(ii) of the Rehabilitation Act, to ensure that the personnel have a 21st century understanding of the evolving labor force and the needs of individuals with disabilities.
DVR has established minimum education and experience requirements for all positions providing rehabilitation services to ensure personnel have a 21st century understanding of the evolving labor force and the needs of individuals with disabilities. All professional and paraprofessionals providing vocational rehabilitation services are required to possess the requisite knowledge, skills, and abilities to perform their job duties. In addition to the education requirements described in section i(3)(A), Rehabilitation Counselors must possess at least 2 years of experience working directly with individuals with disabilities providing relevant services. Similarly, Business Outreach Specialists must possess a Bachelor’s Degree with experience demonstrating candidates have the foundational skills needed for success in the position. DVR managers regularly consider whether recruitment and selection processes, as well as education and experience requirements, for hiring personnel adequately evaluate the qualifications necessary to meet the standard of having a 21st century understanding of the evolving labor force and the needs of individuals with disabilities. As warranted, DVR has flexibility to work with the Office of Human Resources or the Department of Personnel and Administration to adjust minimum qualifications and hiring practices to ensure staff are duly qualified.