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.
- b. Comprehensive Statewide Needs Assessment (CSNA).
Section 101(a)(15), (17), and (23) of the Rehabilitation Act require VR agencies to provide an assessment of:
- b. Comprehensive Statewide Needs Assessment (CSNA).
b. 1. A. Individuals with the most significant disabilities and their need for Supported Employment;
Current Narrative:
Every three years, the Colorado Division of Vocational Rehabilitation (DVR) and the State Rehabilitation Council (SRC), jointly develop and conduct a comprehensive statewide assessment of the rehabilitation needs of individuals with disabilities in Colorado. The triennial Comprehensive State Needs Assessment (CSNA) was developed and conducted in the fall of 2021. Additional strategic planning activities were completed through 2022.
Approximately 70% of individuals served by DVR are those with the most significant disabilities. When it comes to meeting the rehabilitation needs of this population, the key findings from the CSNA demonstrate a need for increased provider development, particularly for supported employment and customized employment services. DVR has not seen a significant increase in demand for these services over the last several years. However, as Employment First is implemented in Colorado, there are changes within the system that may be contributing to this need for provider development.
In 2018, the legislation was passed requiring supported employment service providers to complete nationally recognized training or obtain nationally recognized certification in supported employment. The legislation allowed for a 5-year transition period for existing providers and new providers must be fully qualified within 1-year, and included an appropriation to the Colorado Department of Healthcare Policy & Financing to reimburse providers for training costs. The legislation is within its final year of implementation and funding. The legislation coincided with implementation of Customized Employment in Colorado. While some providers are completing training, the capacity lags what is anticipated to fully meet demand, with just under 300 providers being fully qualified at the time the CSNA was completed. In the last two years, staff turnover among providers has limited expansion of fully qualified providers. As Employment First principles and policies continue to be further developed in Colorado, demand is expected to increase. Additionally, Colorado passed legislation in 2021 phasing out subminimum wage by July 1, 2024. The legislation restricted new individuals from entering subminimum wage employment, and in the summer of 2023, subminimum wage employment in Colorado was eliminated.
At the time of the CSNA, reimbursement rates for these services had remained stable within both DVR and Medicaid Home and Community Based Waivers. As the cost of business has increased for provider agencies, reimbursement rates did not allow agencies to pay wages commensurate with the skill and competency required to perform this work. Low wages are believed by most provider agencies and many stakeholders to be a contributing factor to what has become a direct service labor crisis throughout much of Colorado. This wage discrepancy has been increasingly challenging for providers as minimum wages have increased and many low-skilled, entry level positions in other industries now pay similar or higher wages, yet those who are successful providing job development and job training services to individuals with the most significant disabilities demonstrate competence in a number of areas. In the summer of 2023, DVR worked to increase rates for all job related services, including job search and placement services, job coaching, supported employment and customized employment. DVR is hopeful the increased rates will support recruitment and retention of qualified providers and support the ability of service providers to ensure adequate wages to their employees providing these services.
Similar findings were found related to access to universal technology. As DVR, providers, and people receiving services continue to adjust to hybrid services, it is critical for all people receiving services to have access to necessary technologies, as well as the digital literacy needed to be successful. Further, DVR has begun to take advantage of various technological methodologies for delivery disability related skills training and job training services. As various applications are developed that allow for these services to be provided remotely by a trained provider through a smartphone or similar device, individuals are able to more efficiently access the necessary support. Others with significant disabilities may be more independent and have more expanded options for competitive integrated employment through the availability of assistive technology. DVR has found that nearly all applicants have access to and comfort using the internet and a smartphone, but access and comfort diminishes across other types of technology, with many individuals reporting they are not aware of what assistive technology might be available to them and/or they do not have experience using assistive technology. Individuals reported lack of access to assistive technology such as magnifiers, screen readers, speech to text software, etc. DVR's Personal Adjustment Training (PAT) staff strive to provide access and training to individual's who require this support. Additionally, DVR partners with the Center for Inclusive Design & Engineering (CIDE) through the University of Colorado Denver, which administers that Assistive Technology Act Program in Colorado, to provide training to staff, as well as ensure evaluation, device demonstrations, training, etc., to increase access to needed assistive technology.