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Division Policy 2.11


Substantiality of Services


July 9, 2003


January 18, 2013


This policy will be reviewed and updated as needed.


To ensure that appropriate and substantial services are being provided to individuals with disabilities.


34 CFR 361.47(a)(14)


“Substantial” vocational rehabilitation services are those services which, provided in the context of the counseling relationship, collectively and significantly contribute to the achievement of an employment outcome consistent with the informed choice of the individual.

The Florida Division of Blind Services requires the following information to be included on each consumer’s Certificate of Eligibility:

  1. A description of how the consumer’s visual impairment constitutes or results in a substantial impediment to employment;
  2. A description of the vocational rehabilitation services that the consumer requires to prepare for, secure, retain, or regain employment; and
  3. Indication of presumed eligibility based on the receipt of Social Security benefits.
  4. Description of how the consumer can benefit in terms of an employment outcome from the provision of vocational rehabilitation services.

A disability summary that describes the bilateral visual impairment is required for all eligible consumers of vocational rehabilitation services.

Individual Plan of Employment (IPE)

  • Services identified in a consumer’s IPE must be necessary for the achievement of an employment outcome.
  • All services that are provided must be included on the IPE.

The determination of whether the individual received substantial services must be made on a case-by-case basis. The determination is based on individual needs. When considering whether the services provided meet the definition of substantiality, the reviewer should identify all the needs that should have been met in the IPE, its amendments, and elsewhere in the service record. These needs should include both those pertaining to the vocational abilities of the individual and those relating to the barriers to employment posed by the disability or disabilities.

Original signed by Joyce Hildreth, Director, on October 14, 2009.

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