20 CAR pt. 835, Appendix H
Pre-Employment Transition Services
| Page | |
|---|---|
| Pre-Employment Transition Services | H-1 |
| Definitions | H-2 |
| Pre-ETS Procedure | H-3 |
| Pre-ETS Referral | H-5 |
| General VR and Transition Services | H-5 |
| Memoranda of Agreement | H-6 |
| Memoranda of Understanding with LEA's | H-6 |
| 511 Subminimum Wage Functions and Responsibilities | H-7 |
| Compliance and Monitoring | H-9 |
| Performance and Accountability | H-9 |
Pre-Employment Transition Services (Pre-ETS) are the earliest set of vocational rehabilitation services that a student can receive. The student must at a minimum meet the potentially eligible guidelines set forth in 361.48 (a)(1) meaning all students with disabilities regardless of whether they have applied or been determined eligible for vocational rehabilitation services is provided to individuals meeting the student with a disability definition. The term potentially eligible is applicable ONLY when implementing the requirements governing Pre-ETS. WIOA requires the following five categories be provided to students in Pre-Employment transition:
Job exploration and assessments designed to determine career direction are intended to foster motivation, consideration of opportunities and informed decision-making. Real-world activities ensure that students recognize the relevance of high school and post-school education to their futures, both in college and/or the workplace. Career exploration must be done utilizing industry recognized assessments that will assist the student to choose a career path based on interests, skills, and strengths.
This may include in-school or after school opportunities, or experience outside the traditional school setting (including internships), that is provided in an integrated environment in the community to the maximum extent possible. Work Based Learning will be done in an integrated setting utilizing work experiences where the student works and earns a wage at or above minimum wage. It is expected that supervision will be provided on job sites. Supervision of multiple students on a worksite is allowable so long as the students have individualized work. The number of student work experiences hours shall not exceed 20 hours per week per school year and/or the number of hours per work experience, as set forth by the department of labor. If additional time is required, the counselor will send a justification to the District Manager for approval. For an exception form refer to Appendix G. Students may receive a stipend through Arkansas Rehabilitation Services for time worked during a work experience; however, all stipends must be paid at minimum wage and adhere to Pre-ETS procedures.
Training to inform about career options, and the types of academic and occupational training needed to obtain the careers identified in the job exploration assessments. Training to learn about, prepare for, and/or apply for opportunities outside of high school that will lead to employment. This may include test preparations and testing for entry into post-secondary training.
Workplace readiness will focus on teaching soft skills needed in the work environment, communicating at work, and learning independent living skills. Curriculums, strategies, and activities will be documented monthly on the ARS monthly progress report form, indicating what skills were taught and how the students apply the skills they have acquired.
5. Instruction in self-advocacy (including instruction in person centered planning), which may include peer mentoring.
Self-advocacy can include how to communicate, convey, negotiate or asserting interests and/or desires. Additionally, curriculums can include disability understanding, disability disclosure, decision making, goal setting, evaluate options, identifying accommodations, requesting & utilizing accommodations, providing the knowledge of how to request & accept help, assisting the students in developing intrinsic motivation, developing problem solving skills, assisting with developing positive self-talk.
The school's written plan to meet educational goals and objectives for a student with a disability is called an Individualized Education Program (IEP). The IEP must include a statement of the student's present levels of academic achievement and functional performance. It must also include how the student's disability affects his or her involvement and progress in the general education curriculum, that is, the same curriculum as for students without disabilities. 34 CFR Section 300.320.
Student with a disability is an individual with a disability in a secondary, postsecondary, or other recognized education program who:
Youth with a disability: An individual with a disability who is not:
Youth with a disability is defined as anyone ages 14-24 with the most significant disabilities. The Workforce Innovation and Opportunity Act (WIOA) requires that 50
percent of our Supported Employment funding be spent on the provision of Supported Employment services for youth with disabilities.
Guidelines set forth in WIOA (361.48 (a)(1) ) state: All students with disabilities regardless of whether they have applied or been determined eligible for vocational rehabilitation services is provided to individuals meeting the student with a disability definition. The term potentially eligible is applicable ONLY when implementing the requirements governing Pre-ETS.
The intent of Pre-ETS is to provide pre-employment services to high school student prior to determining eligibility and to expose high school students to the world of work.
1. Students must be in the ARS case management system prior to the initiation of Pre-ETS services.
2. Counselors will utilize the case management system in providing pre-employment transition services for potentially eligible students in status 00.
3. Transition students who receive Pre-ETS services must have the following documentation uploaded into the clients ECF: a. informed consent b. copy of the SS Card and/or documentation verifying social security number c. photo ID (Drivers License, State issued ID, and/or school ID) d. A copy of the students IEP, 504, or documentation to support disability
4. The following documents are required in the electronic case management system: a. demographic form. b. Referral specifics c. PETS document
5. Counselors should document all Pre-Employment Transition Services through a case note. The case note should include: a. Description of the Pre-employment transition service b. Length of Pre-Employment transition service c. Any pertinent information related to the student and the Pre-employment transition service received.
6. Evaluation of students' progress in the Pre-ETS program at least twice a year, documented through a case note.
Students with disabilities will generally will be referred by school staff in the service area utilizing the pre-employment transition services referral document. Students with disabilities regardless of whether they have applied or been determined eligible for
vocational rehabilitation services are eligible to receive Pre-employment transition services. Students must meet the definition of a student with a disability. Transition students who receive Pre-ETS services must have the following documentation uploaded into the clients ECF: Informed consent, copy of the SS Card and/or documentation verifying social security number, photo ID (Driver's License, State issued ID, and/or school ID), A copy of the students IEP, 504, or documentation to support disability.
Once the Transition counselor receives a Pre-ETS referral and all documentation to initiate services has been received; the counselors will provide verification (via email) to the referral source when the student is ready to begin Pre-Employment transition services.
If a student needs a service outside of the five core areas of Pre-ETS the transition counselor will need to initiate the process to develop an Individualized Plan for Employment (IPE).
If it has been determined a student needs a service outside of the five core areas of Pre-Employment Transition Services the transition counselor will need to initiate the process to develop an Individualized Plan for Employment (IPE)
There must be two contacts a year, evaluating and monitoring a student's progress in pre-employment transition services. The case note should reflect direct face-to-face contact, email conversation, phone conversation with the client, or a letter from the client. The case note should be labeled 'guidance and counseling' and reflect which of the 5 core services the guidance and counseling is targeting in the body of the case note. If contact with the client is not possible, use a letter to document the counselor's attempts to contact the client.
Allowable expenditures are those incurred in carrying out any of the 5 core Pre-ETS services. Allowable expenditures must fit within the scope of itemized Pre-ETS activities. 'Allowability' is dependent on the facts of each situation. Any service outside of the allowable Pre-ETS services will require that the student move from potentially eligible to eligible for vocational rehabilitation services status and an Individualized Plan for Employment must be developed.
Students who are enrolled in a Pre-ETS program and are receiving any of the 5 core Pre-ETS services the following is necessary for authorizing Pre-Employment transition services:
1. Students must be in the ARS case management system prior to authorizing Pre-ETS services
2. Individual progress reports shall be submitted to the local ARS field office utilizing the Pre-ETS progress report on a monthly basis.
3. Progress reports shall reflect the individual's monthly attendance, participation, and activities within the five core areas of pre-employment transition services. Pre-ETS progress reports should be submitted no later than the 10th of the month.
4. Invoices should accompany all progress reports. Invoices must reflect individual Pre-ETS service(s) received, total number of hours participated, and hourly rate (based on Pre-ETS fee schedule) in the five core areas of Pre-employment transition service activities.
Transition services are activities designed for a student to promote movement from school to post-school activities. These activities must be coordinated, goal-oriented, and based on the student's needs and interests. The services include post-secondary education, vocational training, integrated employment (including supported employment and job coaching), continuing and adult education, adult services, independent living, and/or community participation. Transition services must promote or facilitate the achievement of the employment outcome.
Any service that fall outside the scope of the five core Pre-employment transition services will require development of an individualized plan for employment (IPE). Transition services may be provided to a broader population-both students and youth with disabilities; transition services are a continuum and represent the next set of vocational rehabilitation services available to students and youth with disabilities.
Transition student may receive concurrent services which includes VR services and pre-employment transition services. If a transition student has moved through the VR process, and has been determined eligible for VR/transition services, the transition Counselor will:
1. Follow all documentation requirements as set for by ARS policy for facilitating movement from status 00 to status 12 or 18
2. The transition counselor will complete the PETS document in the case management system
3. All services including pre-employment transition services will be documented in the IPE
4. Track measurable skills gains by uploading into the client's ECF: the students secondary school diploma or its recognized equivalent, transcripts and/or report cards.
If a student is participating in a work experience through Pre-ETS and needs additional supports such as job coaching that will require the student to move from potentially eligible to eligible for vocational rehabilitation services adhering to policy and procedures for determining eligibility and development on an individualized plan for employment.
Individual job coaching may be provided to students with a disability and individuals who, because of their disabilities, need intensive job coach supports to obtain and maintain a job in competitive or customized employment, trial work experiences, and/or Pre-ETS work experiences. Individual job coaching is not a Pre-ETS services and will require a student to move from potentially eligible to eligible for VR services. Job Coaching is available for up to 200 hours (unless an exception from the district manager is provided).
For a student to receive job coaching Substantial documentation is required. Substantial documentation can include but is not limited to: Individualized education plan, transition plan and/or other school records which substantiate the need for job coaching.
See Appendix I for the job coaching fee schedule. If additional time is required, the counselor will send a justification to the Manager's for approval. For an exception form refer to Appendix G.
The purpose of the Memorandum of Agreement is to define the allowable activities and procedures for receiving payment for services rendered through vendors. The agreements define what services, curriculums and activities a vendor is approved to provide through fee-for-service arrangements with Arkansas Rehabilitation Services. It also lists the roles and responsibilities of the vendor and ARS in service delivery and receipt of payment for services rendered.
The purpose of the MOU is to set the parameters for providing pre-employment transition core services in the school. The goal of the MOU is to establish access times, number of students to be served, and the required documentation and/or records needed to operate in the school system.
Should the high school be providing any of the 5 core services listed above as part of the school's transition program under IDEA, those services will be listed in the high school's responsibility section and be carried out by the school.
Students will be served who meet IEP, 504 criteria or who have a documented disability. The school will determine what course code to apply to the services, if any and determine how credits will be applied to the services, as appropriate. The school will also ensure that students enrolled in the program will meet graduation credit requirements.
Once all parties have signed the MOU with the school, it is distributed to all parties to begin service provisions following the steps outlined in the MOA and the Letter of Engagement (found on the ARS data drive).
The Counselor will signal to the service provider when all documentation and case management processes have been received and completed to initiate services. The counselor will receive the monthly report forms and timesheets for payment processing.
ARS has developed a subminimum wage flow process and forms located on the ARS shared drive. If a youth with a disability is seeking subminimum wage and has completed secondary education and is 24 years old or younger, he/she cannot start working for less than minimum wage until he/she has had the opportunity to:
1. 1. Receive Pre-employment transition services under WIOA, or
2. 2. Transition services under the Individuals with Disabilities Education (IDEA)
3. 3. Applied for ARS services, in accordance with 34 CFR 361.41(b), and determined—
1. (i) Ineligible for vocational rehabilitation services, in accordance with 34 CFR 361.43; or
2. (ii) Eligible for vocational rehabilitation services, in accordance with 34 CFR 361.42; and 1. A. The youth with a disability had an approved individualized plan for employment, in accordance with 34 CFR 361.46; and 2. B. The youth with a disability was unable to achieve the employment outcome specified in the individualized plan for employment, as described in 34 CFR 361.5(c)(15) and 361.46, despite working toward the employment outcome with reasonable accommodations and appropriate supports and services, including supported employment services and customized employment services, for a reasonable period of time; and 3. C. The youth with a disability's case record, which meets all of the requirements of 34 CFR 361.47, is closed.
ARS has a contract in place to ensure that youth with disabilities receive career counseling, and information and referrals supports designed to enable the individual to explore, discover, experience, and attain competitive integrated employment.
1. If a youth is known to be seeking subminimum wage, the Pre-Employment Transition Services and/or Services through IDEA Documentation for Students/Youth Subminimum Wage Employment Form must be completed and uploaded in the clients ECF.
2. If a student has not completed Pre-Employment Transition Services prior to the student exiting the secondary setting the Transition Counselor will place student/youth in Trial Work Experience (Status 06) adhering to the ARS policy and procedures manual. Once the student completes his/her trial work experience and documentation has been obtained and uploaded in the clients ECF, the ARS Transition Counselor will determine the student/youth eligible or ineligible for VR services: a. If a student is determined ineligible the transition counselor will complete the ARS 511 documentation reflecting clear and convincing evidence and follow policy and procedures for closing a case file. b. A signed copy of the ARS 511 SMW document will be uploaded in the clients ECF and a copy will be provided to the student and/or guardian.
3. If a student has participated in Pre-Employment transition services and/or transition services through IDEA and there is clear and convincing evidence the transition counselor will complete the ARS 511 SMW: Pre-Employment Transition Services and/or Services through IDEA Documentation for Students/Youth Subminimum Wage Employment form and close the case file adhering to policy and procedure for closing a case file.
In the event a youth with a disability, or the youth's parent or guardian, refuses through informed choice to participate in services offered by ARS, and that youth is known to be seeking subminimum wage employment, the transition counselor will document the refusal of services by:
1. Completing the ARS Transition Services: Student/Youth Refusal of services document
2. Creating an electronic case utilizing the Demographic form.
3. Uploading the ARS Transition Services: Student/Youth Refusal of services document in the clients ECF.
4. Documenting all activities through a case narrative indicating refusal of services.
5. Providing a signed copy of the ARS Transition Services: Student/Youth refusal of services document to the youth, parent, and/or guardian.
The ARS forms are provided in an accessible format when needed/requested to the youth no later than 45 calendar days after the determination or completion of the required activity or service. It can be as much as 90 calendar days, if additional time is necessary due to extenuating circumstances.
Extenuating circumstances should be interpreted narrowly to include circumstances such as the unexpected lengthy absence of the educational or designated State unit personnel
necessary for the production of the documentation or the transmittal of that documentation due to illness or family emergency, or a natural disaster.
Forms when a youth has refused to participate are provided to the youth within 10 calendar days of the youth's refusal to participate.
Arkansas Rehabilitation Services and its staff will monitor program performance at least annually. A random sample of individual case records will be reviewed to monitor program compliance.
ARS will have access to training sites and training documents and records; ARS will access documents and/or records as well as documents or records created by any agent or contractor authorized to work or to provide services to Pre-Employment Transition participants. Arkansas Rehabilitation Services has the right to conduct confidential interviews with participants and staff that administer the program. Monitoring will also occur upon receipt of a concern from a counselor, participant, parent, program staff or State level personnel.
A scaled performance rubric will be used to measure the effectiveness of the program. The scale will take into account all documentation from the monthly reporting forms, records of the vendor, information gathered from interviews, and information gathered from the ARS case management system. The performance rubric takes into account the services that were provided, the timeframes that services were provided and the overall compliance with the activities and curriculums originally agreed upon in the Memorandums of Agreement. The minimum requirements to meet satisfactory performance are as follows:
1. All reports are due following the service provision as indicated on the performance rubric of the program providing the service.
2. All areas on the monthly report forms and timesheets must be completed.
3. All measures must be met in a rating category in order to achieve that category.
4. The overall score of the Vendor Performance Rubric is based on an average of all of the services that vendor provides.
The Pre-Employment Vendor Performance Rubric and the School Contracted Services Performance Rubric can both be found in the Pre-ETS procedures section of the ARS shared information drive.
Vendors are monitored on a yearly basis unless a compliance form is completed (ARS VC Form 1). The list of complaints and corrective action plans are maintained on the Transition Sharepoint Site at http://acesp.arkansas.gov/agdiv/ars/transition/default.aspx.
If ARS finds that corrective action is required, ARS will provide written notice to the vendor identifying of the requirement requiring corrective action. The vendor will have sixty (60) days from the date of notice to institute policy/procedural changes to rectify the corrective action and present a report to ARS on the corrective action that was taken. Additional time, as is reasonable due to the nature of the issue, and agreed upon by all parties will be negotiated on a situational basis.
At the end of the sixty day period, or such additional time as is reasonable due to the nature of the issue and agreed upon by the parties, in the event that Arkansas Rehabilitation Services determines that appropriate corrective action has not been applied, the Agreement will be brought forward for an administrative review to the Chief of Field Services.
Final disposition on the administrative review will be provided in writing no later than thirty (30) days from the date of the review. Final disposition may include continuation of the service agreement with corrective action or termination of the agreement.