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. 2. Identify the need to establish, develop, or improve community rehabilitation programs within the State.
Current Narrative:
The data concerning the work of Community Rehabilitation Programs collected and analyzed for this study are generally extremely positive. Partners as well as ADRS staff are complimentary about the work of CRPs in the state. CRPs themselves, while expressing some frustrations with the amount and quality of training that they receive from ADRS, feel they are treated as equal partners in the VR system.
The FY 2023 CSNA suggests possible new services for CRPs that might include:
• Expanded Supported Employment services for individuals who have the most significant disabilities. It is further recommended that ADRS assume a more active role in the development of additional funding sources for initial Supported Employment services as well as long-term supports when needed. Partnerships with CRPs and potential new funders should be actively sought. When asked in the initial focus groups to list underserved populations in the state, individuals with the most significant disabilities were the most often mentioned group. In answer to questions about services that are lacking, Supported Employment was consistently listed in the top tier of needed services. These two responses clearly point to the need for additional Supported Employment options, and the state’s network of CRPs can play a vital role in making that goal a reality.
• Expanded School to Work Transition and Pre-ETS opportunities. These services are designed to have a positive impact for students with disabilities at an earlier age which will lead to better coordination, enhanced communication, stronger collaboration, and increased successful post-school outcomes. It seems likely that the need for these services will continue to grow, and opportunities for CRPs to provide viable and needed services should be expanded as well. The need for expanded School-to-Work Transition and Pre-Employment Transition services (Pre-ETS) have been well demonstrated in the past, and these findings have been echoed throughout the focus groups and surveys conducted for this study. The challenge for ADRS will be to find ways to expand the footprint of these valuable services, and the network of Community Rehabilitation Programs is a viable and timely source of providers to assist in this effort.
• Work Based Learning Opportunities. ADRS must develop partnerships between school districts and Alabama transition services to create opportunities for students to participate in work-based learning by providing exposure to the world of work through various experiences. Work-based programs should be made available in as many school districts in the state as possible. These programs provide another opportunity for CRPs to expand their reach into more viable and outcome-based programs.
• Training programs for CRP staff to improve the quantity and quality of needed services. Community Rehabilitation Programs operate on a tight budget and find it difficult to release staff for high quality training that is targeted to the specific needs of the populations they support. It is recommended that ADRS work with CRPs to identify specific training needs and then develop and make available training presentations in formats that are affordable and accessible in local communities.
Specific recommendations from the FY 2023 CSNA are as follows:
It is recommended by the study facilitators that ADRS and representatives from the network of CRPs begin to meet and work to create potential service additions and changes that meet the expanding needs of Alabama’ citizens with disabilities as defined by the agency, while providing an expanded array of services and funding options for CRPs. Possible new services for CRPs might include:
• Expanded Supported Employment services for individuals who have significant disabilities. It is further recommended that ADRS assume a more active role in the development of additional funding sources for initial Supported Employment services as well as long-term supports when needed. Partnerships with CRPs and potential new funders should be actively sought. When asked in the initial focus groups to list underserved populations in the state, individuals with the most significant disabilities were the most often mentioned group. In answer to questions about services that are lacking, Supported Employment was consistently listed in the top tier of needed services. These two responses clearly point to the need for additional Supported Employment options, and the state’s network of CRPs can play a vital role in making that goal a reality.
Lakeshore Rehabilitation Facility: Included in the Community Rehabilitation Program assessment was a specific request by ADRS to evaluate the current needs within the agency operated Lakeshore Rehabilitation Facility. Lakeshore is a comprehensive community rehabilitation program provided localized training in the Birmingham, Alabama area as well statewide services, primarily related to adaptive driving and vocational evaluation. While the CSNA did not assess the quality and quantity of services provided or the overall impact of such services, the reviewers found a complaint regarding the wait time for services and the timeliness of report delivery. The following is taken directly from the CSNA.
ADRS staff were almost universally complimentary about the quality of services provided, but some noted that the amount of time required to make an appointment made the services unusable. The general comments were along these lines: “If I have a person ready to go to work, I just can’t wait 90 days to get them an appointment for a vocational evaluation.
The recommendations from the CSNA are as follows:
The study facilitators recommend that ADRS initiate a thorough analysis of the Lakeshore services system immediately. The continued problems encountered by ADRS staff in terms of timely service delivery and submission of reporting seriously limits the value of the services provided. The evaluators recommend that ADRS leadership thoroughly investigate the program to determine whether changes can be made to increase the value of Lakeshore services to the state’s consumers and the staff who support them. While comments about the services provided by Lakeshore are generally positive, almost all of these positive comments come with this caveat; the wait for appointments and the ensuing wait for follow-up reports renders the service ineffective. The evaluators recommend that an analysis of the return on investment for Lakeshore’s services should be initiated as soon as possible. As part of this analysis, ADRS should evaluate the potential for the network of Community Rehabilitation Programs in the state to provide the critical services currently assigned to Lakeshore.
Centers for Independent Living: While not specifically considered Community Rehabilitation Programs, the CSNA evaluators surveyed staff about their relationship with the state’s Centers for Independent living. The CSNA described the purpose and function of the Centers for Independent Living as follows:
Alabama’s Centers for Independent Living are required to provide these six core services: Peer Support; Information and Referral; Individual and Systems Advocacy; Independent Living Skills Training; Transition assistance from nursing homes and other institutions to community-based residences; Assisting individuals to avoid institutional placement. Alabama is home to four CILs, located in Birmingham (Disability Rights and Resources), Huntsville (Disability Resource Network), Montgomery (Independent Rights and Resources), and Mobile (Mobile Independent Living Center). These centers collectively receive Part C funds in the amount of $1,082,575. An additional $376,352 in Part B funds 79 (Federal funds plus a 10% state matching amount of $37,635) are divided between the four CILs, the SILC, and the DSE.
Centers for Independent Living operate fairly independently. Although the CIL’s in Alabama work cooperatively, each CIL is responsible for ensuring that the core services are provided through their particular center. The CIL’s are philosophically sound and advocate strongly for their consumers. It became clear through the initial focus groups as well as the surveys, however, that there is little if any intentional integration between the CILs and the VRS system as a whole; local VR counselors didn’t express any significant awareness of the CILs work with individuals with disabilities. The existing Centers for Independent Living have service areas that, in total, cover only 15 of 67 counties in Alabama, representing 45% of the state’s population. This is a deficiency that is noted in the draft SPIL that was created in 2020. One of the outreach goals in the SPIL is, “The four CILs will continue to identify both geographical areas and diverse populations within their service areas. All IL services under Title VII, part B are provided directly through the network of centers for independent living. The CIL’s will provide community-based IL core services in all 67 counties, as needed.” This is a commendable goal. The CILs will continue to work hard to provide outreach and to serve those individuals from outlying areas who are most in need, but it is difficult to imagine how this will be accomplished with the current funding.
Recommendations:
While the Centers for Independent Living provide excellent services to the consumers that they reach, there are indeed needs for improvement. These are needs that the CIL’s cannot meet on their own. While the Centers for Independent Living don’t have the authority for making these changes, and don’t bear full responsibility for them, it is important that the needs be documented. The study facilitators recommend the following changes for the Centers for Independent Living:
• The CIL’s should work with the VR system and specifically with ADRS to become a fully integrated and intentional partner with the agency. There are a number of valuable services that are provided by the CIL’s that are not fully understood by the agency; when there is understanding and collaboration, it is too often centered with senior management and is not known or understood by the rank-and-file counselors and staff across the state.
• Centers for Independent Living representatives should have a representative on the State Rehabilitation Council. It is not enough to have a SILC representative on the council. Because the CILs and the SILC are separate and distinct entities, the CILs should have a place at the table. (Note: this representation had recently been vacated at the time the CSNA was conducted and a replacement representative was not yet named.)
• The CILs should work closely with the agency and act as advocates for additional funding to operationalize a 5th CIL in the state. It is not acceptable to have the majority of Alabama’ counties located outside of a CIL service area. In the draft SPIL (2020) an outreach goal was included which addressed the need to expand the network of CILs: “3.2 Expansion and Adjustment of Network: Plan and priorities for use of funds, by funding source, including Part B funds, Part C funds, State funds, and other funds, whether current, increased, or onetime funding and methodology for distribution of funds. Use of funds to build capacity of existing Centers, establish new Centers, and/or increase statewideness of Network.” This is an excellent goal. No information was provided to allow the study facilitators to evaluate the progress toward this goal. The Independent Living philosophy postulates that people with disabilities are the best experts on their needs, and therefore they must take the initiative, individually and collectively, in designing and promoting better solutions and must organize themselves to work together for those solutions. To fully live in this philosophy, Alabama’ CILs must work closer together to advocate for expanded IL services in Alabama.