DIVISION POLICY 2.36
Pre-Employment Transition Services
March 7, 2018
This policy will be reviewed and updated as needed.
Provide guidance on the Pre-Employment Transition Services including purpose, population and specifications.
The Workforce Innovation and Opportunity Act (WIOA) places heightened emphasis on the provision of services to students and youth with disabilities to ensure that they have meaningful opportunities to receive the training and other services they need to achieve employment outcomes in competitive integrated employment. The expansion of the population to be served within the transition from school to employment includes newly defined terms of a "student with a disability" and "youth with a disability." In addition, there are new requirements related to pre-employment transition services and the provision of transition services to students and youth with disabilities.
Vocational rehabilitation services to students and youth with disabilities are provided on a continuum, with pre-employment transition services generally being the earliest set of vocational rehabilitation services available to students with disabilities. Pre-employment services, authorized by section 113 of the Act, as amended by WIOA (34 CFR 361.48(a)), are designed to assist students with disabilities to begin to identify career interests that will be further explored through additional vocational rehabilitation services, such as transition services. In addition, pre-employment transition services are only those services and activities listed in section 113 of the Act, as amended by WIOA (34 CFR 361.48(a)). Job placement assistance is not included among the listed preemployment transition services, but could be constituted as a transition service.
Finally, pre-employment services are available only to students with disabilities, whereas transition services may be provided to a broader population-in school students and out of school youth with disabilities.
DBS will make pre-employment transition services available statewide for all students in need of such services who are eligible or potentially eligible for VR services through DBS.
For those students who are potentially eligible, a full DBS application for services and an IPE are not required. Pre-employment transition services may begin as soon as a student requests or is recommended for one or more preemployment transition services and documentation of a disability is provided to DBS. DBS will reserve not less than 15 percent of the Federal VR allotment to provide, or arrange for the provision of pre-employment transition services for students with disabilities. This policy includes guidance for providing these services statewide, via authorizations and under contracts with Community Rehabilitation Programs (CRPs), in collaboration with state and local education agencies. Please reference the internal policy highlighting the process by which reserved funds are tracked for compliance and reporting.
A. Target Population:
Pre-employment transition services are provided to "students with disabilities" who are eligible for VR services or potentially eligible for VR services.
B. Student with a disability:
In accordance with (section 7(37) of the Act and §361.5(c)(51)), defined as an individual with a disability, age 14 up to 22 years of age, participating in a secondary, postsecondary, or other recognized educational program and:
- eligible for and receiving special education or related services under IDEA, or
- a student who meets the definition of an individual with a disability for purposes of section 504 of the Rehabilitation Act, as amended by WIOA.
In accordance with the Florida Department of Education Interagency Articulation Agreement for the Transition of Students with Disabilities, Pre-Employment Transition Services will be made available for students ages 14, through and including the age of 21, when a student meets all other requirements prescribed by law.
In the event the student does not have a 504 plan or an IEP, the counselor may still provide pre-employment transition services with proper documentation of disability.
Supporting documentation of the disability may include:
- Case note documenting counselor observation, review of school records, statements of education staff or teacher of the visually impaired (TVI); or
- A referral for pre-employment transition services with the identification of a student's disability, signed by education staff and a parent/guardian, if the student is under 18 years of age (parental consent to participate in pre-employment transition services is governed by Florida law, as well as policies of the Florida Department of Education, local school districts and the Division of Blind Services); or
- Copy of an individualized education program (IEP) document, SSA beneficiary award letter, school psychological assessment, documentation of a diagnosis or disability determination or documentation relating to 504 accommodation(s).
C. Potentially Eligible:
As defined in 34 CFR361.48(a) means all students with a disability, who satisfy the definition in 34 CFR361.5(c)(51), regardless of whether they have applied for or have been determined eligible for VR services. This term is unique to implementing pre-employment transition services and is not applicable to any other Vocational Rehabilitation service. Note: DBS will serve potentially eligible students with visual impairments (as defined in this and other DBS policies and procedures). The Division of Vocational Rehabilitation will serve other potentially eligible students.
D. Educational Programs:
Defined as Secondary education, Non-traditional or alternative secondary education programs including home schooling, adult basic educational programs; which lead to a recognized educational credential (e.g., GED or high school diploma); alternative school programs (e.g., those housed within the juvenile justice system); post-secondary education programs approved by a state's Higher Education Commission; and state, nationally, or industry recognized certificate programs leading to a credential.
Documentation confirming enrollment may include an IEP, 504 Plan, report card, college acceptance letter, college registration receipt, or other documentation from the educational program.
3. Pre-Employment Transition Services
Pre-employment transition services are designed to be an early start at job exploration, to assist students with disabilities in identifying career interests, and to learn skills in preparation for transition to employment and/or post-secondary education, to be further explored through additional VR services, including transition services.
Pre-employment transition services are those that would be most beneficial to an individual in the early stages of career exploration during the transition process from school to post-school activities, including employment ("Big 5"). If a student needs more individualized services (e.g., job coaching, travel expenses, uniforms or assistive technology), he or she would need to apply, be determined eligible for transition and/or vocational rehabilitation services, and develop and have an approved individualized plan for employment. If Orientation and Mobility training is required to participate in a work-based learning experience and/or workplace readiness training, the Pre-Employment Transition Services funding may be used, Otherwise, VR funds must be utilized for any orientation and mobility not specifically related to pre-employment transition services.
Pre-employment transition services [Section 7(30) of the Act and §361.5(c)(42)] are:
A. Required Activities
The following five "required" activities of preemployment transition services which can be provided in a group or general classroom setting and/or on an individual basis under section 113 of the Act and §361.48(a) of the VR regulations are:
- Job Exploration Counseling
- Group: Job exploration counseling in a group setting may be provided in a classroom or community setting and could include: (1) Information regarding in-demand industry sectors and occupations, as well as nontraditional employment; (2) Information about labor market composition; (3) Administration of vocational interest inventories, and identification of career pathways of interest to the students.
- Individual: Job exploration counseling provided on an individual basis may be provided in a classroom or community setting and could include discussions pertinent to the student about: (1) the student's vocational interest inventory results; (2) in-demand occupations; (3) career pathways; and (4) labor market information that applies to the student's interests.
- Work Based Learning Experiences - May include opportunities that are in-school or after school, or outside the traditional school setting (including internships), provided in an integrated setting in the community to the maximum extent possible. DBS should exhaust all opportunities for work-based learning experiences in integrated settings before placing an individual in a nonintegrated setting.
- Group: Work-based learning experiences in a group setting may include: (1) coordinating a school-based program of job training and informational interviews to research employers; (2) work-site tours to learn about necessary job skills; (3) job shadowing; or (4) mentoring opportunities in the community.
- Individual: Work-based learning experiences on an individual basis could include paid or unpaid: (a) internships, apprenticeships (not including pre-apprenticeships and registered apprenticeships); (b) short-term employment, fellowships, or on-the-job trainings located in the community.
*Pre-Employment Transition Service funds for work-based learning experiences must be used solely to pay for those costs incurred in the direct provision of Pre-Employment transition services; and must solely be for the benefit of a student with a disability.
The following are broad examples of types of costs that might be allowable for purposes of providing work-based learning experiences with the funds reserved for the provision of pre-employment transition services: -- (1) Interpreters, reader services, accessible informational materials necessary to ensure equal access to the work-based learning experience, as required by the ADA or section 504 of the Rehabilitation Act; (2) Fees charged by the employer for providing the experience, which may include the costs for: Printing of additional informational materials or the purchase of additional uniforms for the student; Internships; Apprenticeships; Short-term employment Fellowships; On-the-job trainings located in the community; or the employer-provided staff or trainer who teaches the job tasks to the students or other costs incurred by the employer in providing the workbased learning experience to the students, which are not individualized in nature.
- Counseling on opportunities for enrollment in comprehensive transition or post-secondary educational programs at Institutions of Higher Education (IHE's).
- Group: Counseling on these specific opportunities in a group setting may include providing information on: course offerings; career options; the types of academic and occupational training needed to succeed in the workplace; and Post-Secondary opportunities associated with career fields or pathways.
- Individual: Such counseling may also be provided on an individual basis and may include: advising students and parents or representatives on academic curricula; providing information about college application and admission process; completing the FAFSA; and providing resources that may be used to support individual student success in education and training (disability support services).
- Workplace readiness training to develop social skills and independent living
- Group: Workplace readiness training services may be offered in a generalized manner in a classroom or other such group settings to provide programming to assist students with disabilities to develop social skills and independent living skills necessary to prepare for eventual employment. These series could teach skills such as: communication and interpersonal skills; financial literacy; group orientation and mobility skills (to access workplace readiness training or to learn to travel independently); job seeking skills; understanding employer expectations for punctuality and performance, as well as other 'soft' skills necessary for employment; and on-site workplace readiness training during a work-based learning experience.
- Individual: All of the above group workplace readiness training may be tailored to an individual's needs in a work readiness training program provided in an educational or community-based setting through instruction, as well as opportunities to acquire and apply knowledge.
- Instruction in self-advocacy, which may include peer mentoring
- Group: Instruction in self-advocacy services may be provided through generalized classroom lessons in which students: learn about their rights and responsibilities; learn how to request accommodations or services and supports; communicate their thoughts, concerns, and needs, to prepare them for peer mentoring opportunities with individuals working in the area(s) of interest.
- Individual: These services can also be provided through individualized opportunities that include students: conducting informational interviews; mentoring with educational staff; mentoring with individuals employed by or volunteering for employers, boards, associations, or organizations in integrated community settings; and participating in youth leadership activities offered in educational or community settings.
B. Authorized Activities:
The following nine authorized activities may be carried out using funds remaining from those reserved for pre-employment transition services after required activities have been made available statewide for all students with disabilities who need them.
- Implementing effective strategies to increase the likelihood of independent living and inclusion in communities and competitive integrated workplaces
- Developing and improving strategies for individuals with intellectual disabilities and individuals with significant disabilities to live independently, participate in postsecondary education experiences, and obtain and retain competitive integrated employment.
- Providing instruction to vocational rehabilitation counselors, school transition personnel, and other persons supporting students with disabilities
- Disseminating information about innovative, effective, and efficient approaches to achieve the goals of this section
- Coordinating activities with transition services provided by local education agencies under the Individuals with Disabilities Education Act (20 USC. 1400 et seq.)
- Applying evidence-based findings to improve policy, procedure, practice, and the preparation of personnel, to better achieve the goals of preemployment transition services
- Developing model transition demonstration projects
- Establishing or supporting multistate or regional partnerships involving States, local education agencies, designated State units, developmental disability agencies, private businesses, or other participants to achieve the goals of pre- employment transition services, and
- Disseminating information and strategies to improve the transition to postsecondary activities of individuals who are members of traditionally unserved populations.
C. Coordination Activities:
Pre-employment transition coordination activities (section 113(d) of the Act and §361.48(a)(4)) may be necessary for arranging and providing direct pre-employment transition services. These activities can be paid for using funds reserved for Pre-ETS when a client is receiving services under the Big 5. Pre-employment transition coordination activities are:
- Attending IEP meetings, when invited;
- Working with the local workforce development boards, one-stop centers, and employers to develop work opportunities for students with disabilities;
- Working with schools to coordinate and ensure the provision of preemployment transition services; and
- Attending person-centered planning meetings for students with disabilities receiving services under title XIX of the Social Security Act, when invited.
The Individuals with Disabilities Education Act (IDEA) and Rule 6.4-6.03028, Florida Administrative Code, require that representatives from agencies that may be responsible for providing or paying for transition services be invited to individual educational plan (IEP) meetings. Counselors are expected to attend the student's Admission and Release Committee Meeting/lndividualized Education Program meeting or 504 plan meetings as early as age 14 through and including 21, and act as a consultant in the student's IEP. If the Counselor is unable to attend the meeting in person, alternative methods such as webcam or a teleconference are allowable means of communication. Early contact and intervention with a student and family allows significant opportunities for planning and development. This process allows the student to make well-informed decisions about their employment goals given their unique strengths, resources, priorities, concerns, abilities, capabilities, and informed choice. Counselors should partner with the school/educational agency utilizing the available statewide or regional programs to facilitate the process of providing Pre-Employment Transition Services. If students need a service not readily available, the Counselor may work with the school, or another provider, to facilitate the coordination of services. The five required activities will be provided directly by the CRPs, contracted providers, the counselor and other DBS staff, where appropriate.
4. Auxiliary Aids, Other Accommodations and Services
Auxiliary aids, other accommodations and services can be provided if required for participation in Pre-ETS regardless of VR case status or financial need and charged to the Pre-ETS funds. Outside of the provisions below, if a student requires any services other than those activities defined under the Pre-ETS required activities, then the student should consider applying for the VR program to access VR transition services under an IPE.
Interpreting: Interpreting services may be provided in conjunction with Pre-ETS and may be charged to the Pre-ETS funds if this service is required for a student(s) to access the specific Pre-ETS service(s) being provided.
Assistive technology: Assistive technology may be purchased to support general access to an event or activity, such as a work-based learning experience and may be charged to the Pre-ETS funds.
DBS will ensure that no qualified student with a disability is denied the benefit of pre-employment transition services on the basis of the individual's disability. Therefore, if a student with a disability requires reasonable accommodations/auxiliary aid or service to access or participate in any of the required pre-employment transition services, DBS may pay for such costs when no other public entity is required and/or available to provide such aid or service.
Reasonable Accommodation/Auxiliary Aids and Services
A. Accommodations, aids and services for deaf and hard-of-hearing students, including:
- Qualified interpreters on-site or through video remote interpreting (VRI) services
- Note takers
- Real-time computer-aided transcription services
- Written materials
- Exchange of written notes Telephone handset amplifiers
- Assistive listening devices
- Assistive listening systems
- Telephones compatible with hearing aids
- Closed caption decoders
- Open and closed captioning, including real-time captioning
- Voice, text, and video-based telecommunications products and systems, including text telephones (TTYs, videophones, and captioned telephones, or equally effective telecommunications devices
- Videotext displays
- Accessible electronic and information technology
- Other effective methods of making aurally delivered information available to individuals who are deaf or hard of hearing
B. Accommodations, aids and services for blind, visually impaired and deafblind students, including:
- Support Services Provider (SSP) for the deaf-blind
- Qualified readers Taped texts
- Audio recordings
- Braille materials and displays
- Screen reader software Magnification software
- Optical readers
- Secondary auditory programs (SAP)
- Large print materials
- Accessible electronic and information technology
- Other effective methods of making visually delivered materials available to individuals who are blind or have low vision
C. Assistive technology screenings
To determine whether modified equipment or devices are needed for a student to participate in preemployment transition services.
D. Pre-ETS funds
Pre-ETS funds may not be used to modify a student's personal equipment or devices, or to provide personal equipment or devices of which students would retain ownership.
E. Auxiliary aids and services do not include:
- Personal devices (e.g., computers, laptops, tablets, etc.)
- Prescribed devices (e.g., eyeglasses, hearing aids, wheelchairs)
- Readers for personal use or study
- Attendant Care or other services of a personal nature
- Home or vehicle modifications
F. Other examples of unallowable costs include:
- Transportation costs for students with disabilities receiving a preemployment transition service
- Lodging and meals for a student with a disability receiving a preemployment transition service
- Job Coaching services
- Staff time spent providing other VR services that do not fall under the definition of pre-employment transition services
5. Provision of Other Necessary Support Services
Funding of services needed shall be determined in collaboration with the local school system and other resources. School officials continue to be responsible for providing a free and appropriate public education to include transition services required under IDEA.
If a student with a disability requires personal devices or services or individuallyprescribed assistive technology, or maintenance, transportation or other individualized services; the student would need to apply and be determined eligible for TS or VR services, and these services would need to be agreed upon and identified on an individualized plan for employment (IPE) in accordance with section 102(b) of the Rehabilitation Act for the provision of those additional services.
6. Outreach and Collaboration Responsibilities
DBS staff will make every effort to develop and maintain cooperative working relationships with state and local secondary education staff (including alternative school programs), post-secondary education staff, state operated programs, and workforce development partners (e.g., CareerSource, Department of Economic Opportunity, etc.) to coordinate pre-employment transition services.
Coordination activities include:
- Participating in Individualized Education Program (IEP) meetings for both eligible and potentially eligible students. Participation may be in person or by teleconference, when invited, pending DBS representative availability.
- Making every effort to attend person-centered planning meetings for students with disabilities receiving services under title XIX of the Social Security Act, when invited.
- Working with CareerSource, other WIOA Programs, and employers to develop work-based learning experiences for students with disabilities.
- Encouraging referral sources to refer students with disabilities in secondary education as early as age 14 for pre-employment transition services and to check on the status of these referrals.
- Providing accurate information to referral sources regarding the timeline and application process for vocational rehabilitation services.
School officials continue to be responsible for providing a free and appropriate public education to include transition services required under IDEA.
7. Provision of Pre-Employment Transition Services to Students with Disabilities
- Students who may receive Pre-Employment Transition Services include:
- Students who are legally blind and who have applied for and been determined eligible for vocational rehabilitation services: These students may receive Pre-ETS services and TS/VR services.
- Students who are visually-impaired, who have applied for and been determined eligible for transition/vocational rehabilitation services: Students who meet DBS eligibility have a visual acuity of 20/70 or less, or a visual field no greater than 20 degrees radius, in the better eye after correction. These students may receive both Pre-ETS services and TS/VR services.
- Students who are legally blind or visually-impaired and have not applied for DBS transition/vocational rehabilitation services: Students who would qualify for DBS transition/vocational rehabilitation services but have not applied (and who may not wish to do so, at this time) are "potentially eligible." These students may only receive Pre-ETS services -- via authorizations (not under the contract).
- Students who school staff consider as having a significant bi-lateral visual impairment and are not receiving services through DBS: Students with a significant visual impairment, who are not DBS clients, and whose exact medical condition and prognosis may not be known are "potentially eligible." These students may only receive Pre-ETS services -- via authorizations (not under the contract).
Note: for the purposes of determining potential eligibility, where the term, vocational rehabilitation is used, it refers to both transition services and vocational rehabilitation services.
Pre-ETS services provision to students with disabilities shall be:
- Governed by the DBS' policies and procedures
- Consistent with DBS/CRP contracts for services
- In accordance with: (1) State and federal law and regulation; (2) The statewide educational cooperative agreement
- Made available to students with disabilities statewide, to include those that are "potentially eligible" for VR services.
- Provided based on parental consent to participate in pre-employment transition services obtained pursuant to the State law, as well as policies of the educational programs.
Students with disabilities are not exempt from any of the order of selection requirements for vocational rehabilitation services. A student with a disability who needs individualized VR services, in addition to pre-employment transition services, must apply and be determined eligible for the VR program and have an approved IPE.
8. Pre-Employment Transition Services Referral Process
To ensure that requests for pre-employment transition services are accepted, assigned, and registered in AWARE promptly, referrals of students with disabilities shall be managed as indicated below:
- A referral may be submitted by school personnel, family members, guardians, or other interested persons via an online referral form, paper referral form, or verbally (such as by phone). Referral information should include:
- Social security number (optional, not included when the online referral process is used, and may also be collected on Pre-ETS Student Information Form.);
- Date of birth;
- Student Identification Number
- DBS staff shall establish referral procedures with local school officials to assure that:
- Parent/Guardian consent for DBS collaboration with the school is obtained.
- Student referred for pre-employment transition services meet the definition of "student with a disability.'
- Student has medical and/or school documentation substantiating that the individual is a student with a disability (e.g., the IEP, 504 plan or doctor's note) for purposes of providing pre-employment transition services,
- Referrals from school personnel include pertinent and available school-based assessment information (e.g., psychological evaluations, vocational evaluations, and medical or specialty screenings including eye medical report), in the event the student applies for vocational rehabilitation services.
- For potentially eligible students, services shall be paid for on a PE (Potentially Eligible) Case Type via authorizations in accordance with DBS established protocols.
- For students who have applied for and been determined eligible for Vocational Rehabilitation Services, services shall be paid for using the DBS/CRP contract, unless less comprehensive services are warranted under the authorization's process.
- Student information shall remain in the referral module until all information required for Pre-Employment Transition Services is completed and received in its entirety.
If all required documentation is not provided or the student or parent/legal guardian does not respond to a minimum of two documented DBS contacts, the referral may be closed and the student notified accordingly.
Upon receiving the referral, the rehabilitation technician will contact the applicant, explain their options and then the individual (and/or guardian) will make the decision whether to pursue a PE, TS, or VR case. If the individual (and/or guardian) selects potentially eligible, the new "PE" case will be created in the Participant Module where it will be linked to the referral. If a TS or VR case selection is made, the application will follow the eligibility determination process.
9. Documenting Pre-Employment Transition Services
The need for and provision of Pre-ETS services, and the student's agreement to receive these services, will be documented in the AWARE system via case notes. The Referral shall be maintained in the attachment section of the AWARE system.
10. Financial Responsibility for Pre-employment Transition Services
Pre-ETS services are not contingent on a student's financial need. The Division's financial need policy and the possibility of a family contribution will not apply when the student participates in pre-employment transition services.
Non-Contract services are subject to the Service Fee Schedule established rates for Pre-Employment Transition Services.
11. Discontinuation of Pre-Employment Transition Services
A. Pre-employment transition services shall be discontinued:
- Once an individual no longer satisfies the definition of a "student with a disability." However, if the individual also receives other program services under an IPE (i.e., has been determined eligible for services), he/she will continue to receive those services by DBS that are applicable to his/her IPE, but will no longer qualify for Pre-ETS.
- When the individual chooses not to participate in, or continue participating in pre-employment transition services, as confirmed by student and/or guardian either verbally or in writing.
When the client is no longer a "student with a disability," the AWARE system will automatically remove the "Big 5" services as an option for Authorizations and Actual Service entries and the client will no longer be able to receive these services under Pre-ETS. This does not prevent individuals from continuing to receive other transition or rehabilitation services if the individual is otherwise eligible for these services and the services have been appropriately planned.
At the time of service discontinuation, the DBS counselor or supervisor should make every attempt to contact the individual to notify them, and documentation of the discontinuation of services should be provided through the appropriate closure letter. The record of services shall be closed in AWARE when services have been discontinued.
Signed by Robert L. Doyle, Ill, Director, on 4/30/2018.