Summary of Input and Recommendations of the State Rehabilitation Council; Response of the Designated State Unit; and Explanation for Rejection of Input or Recommendations: Attachment 4.2(c)

The State Rehabilitation Council (SRC) is mandated under the Rehabilitation Act to work in partnership with the Office of Adult Career and Continuing Education Services - Vocational Rehabilitation (ACCES-VR). Together, the SRC and ACCES-VR partner to ensure that individuals with disabilities receive timely and effective vocational rehabilitation services. The SRC relies on the following committees to carry out its responsibilities: the Executive Committee; the Membership Committee; the Policy and Procedures Committee; the Quality Assurance and Improvement Committee and the Workforce Development Committee. The SRC Chairperson, Committee Chairpersons and the ACCES-VR SRC Liaisons constitute the Executive Committee that coordinates the work of the committees based on their strategic planning and the statutory obligations of the SRC.

ACCES-VR and the SRC work cooperatively in setting strategic priorities and in developing agency policy for the delivery of vocational rehabilitation services for eligible New Yorkers with disabilities. ACCES-VR convenes ad hoc policy development committees when undertaking substantive policy changes. These committees are typically chaired by an ACCES-VR policy and partnerships unit staff person along with representation from VR management, vocational rehabilitation counselors and key stakeholders. A SRC representative has served as an integral part of every ACCES-VR ad hoc policy development team convened over the course of the reporting period.

The following is a summary of recommendations made by the New York State Rehabilitation Council over the course of Federal Fiscal Year 2010:

ACCES-VR Policies and Operations

SRC Recommendations: The SRC strongly supported ACCES-VR's efforts to avoid implementing an order of selection (OOS) and recommended several changes to the proposed criteria established for implementation of an OOS. In addition, the SRC expressed strong support for the New York State Education Department (SED) and the NYS Office of State Comptroller to approve hiring new VR counselors.

ACCES-VR Response: ACCES-VR found the SRC review of the draft OOS criteria very helpful in examining the cross set of considerations associated with the development of the ACCES-VR OOS policy and procedures. Based on SRC input, the criteria for implementing an OOS was modified to include tracking the nature and scope of complaints from ACCES-VR's Quality Assurance Unit and the New York State Client Assistance Program. The SRC also contributed to setting minimum counselor to consumer ratios to maintain ACCES-VR's capacity to deliver services.

SRC Recommendations: ACCES-VR should modify their consumer satisfaction survey to include individuals who had received services under an individualized plan for employment (IPE) but were closed unsuccessfully (status 28 consumers).

ACCES-VR Response: ACCES-VR amended its consumer satisfaction survey protocols to include status 28 consumers.

SRC Recommendations: ACCES-VR should update its policies and primary forms and brochures to support the full participation of eligible ACCES-VR consumers with limited English proficiency (LEP). The SRC also recommends that key ACCES-VR outreach materials, forms and brochures be made available in other languages and reviewed by a cross-section of representatives from these communities.

ACCES-VR Response: With SRC input, ACCES-VR established statewide policy and procedures to assist VR counselors procure language interpreter services. ACCES-VR also revised several key brochures to ensure their availability in alternative languages. The brochures that were translated included: “Applications for VR Services”, “A Guide for Developing Your Individualized Plan for Employment (IPE)”, “ACCES-VRs Basic Guide”, “What Can I Do If I Disagree with the ACCES-VR IEP Decision about My Case”. These documents were translated into Spanish, Russian, Mandarin Chinese and Haitian Creole and distributed to ACCES-VR for distribution to interested consumers.

SRC Recommendations: ACCES-VR might develop more efficient strategies for conducting their federally mandated comprehensive statewide needs assessment to include the identification of available and ongoing data sources and consider collaborating with other agencies represented on the SRC that have similar obligations to conduct needs assessments.

ACCES-VR Response: SRC made a substantive contribution to ACCES-VR's approach to undertaking its most recent comprehensive needs statewide assessment and will continue to work with the SRC Quality Assurance Committee to develop more efficient and collaborative approaches to developing future assessments.

SRC Recommendations: ACCES-VR should consider instituting internal mechanisms for sorting key service delivery and outcome data on a regional basis. These data would inform and support district office managers in meeting unique local and regional needs and might serve to highlight regional variations in service delivery trends.

ACCES-VR Response: ACCES-VR is in the process of developing performance indicators for its Unified Contract Services (UCS) that will assess the requisite resource requirements to sort service delivery and outcome data on a regional basis.

SRC Recommendations: Replicate the Model Transition Program (MTP) initiative and undertake activities to sustain partnerships and best practices established under MTP.

ACCES-VR Response: ACCES-VR has worked with Cornell University to analyze the data from the MTP, and includes the identification of best practices. Results are available on their website. In addition, there is training available from the Rehabilitation Research and Training Institute (RRTI) that can be found on RRTI’s web site.

SRC Recommendations: Identify opportunities to better integrate employers into the rehabilitation process.

ACCES-VR Response: The City University of New York (CUNY) Linking Employment, Academics and Disability Services (LEADS) initiative has placed significant emphasis on facilitating student access to ACCES-VR sponsored internships. The ACCES-VR Syracuse District Office is also working closely with the Office for Disabled Student Services and the Career Service Offices at Onondaga Community College and LeMoyne College to develop work experiences for students with disabilities to enhance the students overall career development.

SRC Recommendations: ACCES-VR should consider maintaining a close working relationship with the Most Integrated Setting Coordinating Council (MISCC) and Office of Mental Health's (OMH) Medicaid Infrastructure Grant (MIG).

ACCES-VR Response: ACCES-VR continues to coordinate the MISCC Employment Committee and remains fully engaged with the principal managers and stakeholder groups associated with the MIG.

SRC Recommendations: ACCES-VR should commit all records of its consumers served under the UCS into the new MIG interagency database, the One Stop Operating System (OSOS), as soon as the system goes online. The potential of the system expands beyond the coordination of services and offers job postings and job matching resources for employers interested in hiring qualified workers with disabilities. By excluding ACCES-VR consumers from this database, the VR consumer who seeks employment will not have equal access to job openings and will not be represented to NYS employers. In turn, NYS business will not have access to the full spectrum of talent available that exists among NYS residents with disabilities.

ACCES-VR Response: ACCES-VR is committed to the success of the OSOS under development through the MIG. For phase I implementation, ACCES-VR has recommended that all UCS Placement providers and Independent Living Centers have access to the new system.

SRC Recommendations: ACCES-VR should solicit consumer input into the design of the supported employment provider directory. The SRC also recommends that the directory include provider data on successful employment outcomes including the demographic information on disability, age and employment outcomes.

ACCES-VR Response: ACCES-VR identified the primary use of the directory as a reference for VR counselors and will consider how best to make this information available to consumers following an initial rollout of the Supported Employment Information Directory (SEID).

SRC Recommendations: ACCES-VR might consider greater utilization of work related benefits counseling to assist consumers who fear that work activity will jeopardize their benefits. Benefits counseling can be instrumental in assisting consumers negotiate the benefits systems, earnings, asset accumulation and related concerns.

ACCES-VR Response: ACCES-VR has established Unified Contract Services (UCS) with 25 Independent Living Centers statewide and recognizes utilization of these services have been limited. ACCES-VR personnel have been encouraged to make better use of benefits counseling services available through the Social Security Administration's Work Incentive Planning and Advisement (WIPA) network. ACCES-VR is also working with its MIG partners and Buffalo University's Technical Assistance and Continuing Education (TACE) to provide staff development regarding benefits counseling service.

SRC Recommendations: ACCES-VR should adopt and implement the Social Security Administration's Ticket to Work Partnership Plus Program.

ACCES-VR Response: ACCES-VR has committed to participation in the Ticket to Work Partnership Plus Program and appreciates the input the SRC has provided developing and finalizing the new Ticket to Work policy and procedures. ACCES-VR's initial approach to implementing the Ticket Partnership Plus option will be based on referrals to employment networks to assist individuals in maintaining employment over time.

SRC Recommendations: ACCES-VR should work closely with Cornell University in the development of an Employer Web-based Resource Directory.

ACCES-VR Response: Together the ACCES-VR's Statewide Coordinator for Workforce Development and Business Relations and the SRC Workforce Development Committee collaborated with Cornell University in designing and launching the comprehensive Employer Web-based Resource Directory. SRC Recommendations: Review and revise the ACCES-VR Self Employment policy, particularly in light of the work undertaken by the MIG’s NY Makes Work Pay initiative on customized self employment.

ACCES-VR Response: ACCES-VR has conducted several regional meetings among its regional personnel and the self employment service providers (e.g., NYS Small Business Development Centers, Chambers of Commerce and community loan fund programs) to foster more effective local collaborations in support of self employment services and supports. ACCES-VR will continue to evaluate emerging practices, including the Makes Work Pay self employment initiative, to identify value added approaches to supporting self employment and entrepreneurial ventures. These efforts will lay the groundwork for developing more effective practices.

SRC Recommendations: Policy revisions in general should be shared for public comment before finalized.

ACCES-VR Response: ACCES-VR routinely solicits public comment on all significant policy reforms. This feedback is typically solicited during State Plan town meetings and dedicated statewide public forums when the release of these policies fails to coincide with State Plan town meetings.

SRC Recommendations: The SRC should be kept informed of the NYS High School Exiting Summary/Credential that will replace an Individualized Education Program (IEP) diploma.

ACCES-VR Response: The SED’s Office of P-12 Education has assigned a special education program manager to serve on the SRC. The P-12 education representative provides regular updates on the status of development associated with IEP diploma reforms.

SRC Recommendations: The SRC should be kept informed on the status of the National Work Readiness Credential.

ACCES-VR Response: ACCES-VR shares the SRC's interest in tracking the development of this credential. However, limited scheduling time during FFY 2010 did not allow for an updated presentation by the lead agency, NYS Department of Labor. ACCES-VR will arrange for a work readiness update for the SRC in FFY 2011.

SRC Policies and Operations

SRC Recommendations: ACCES-VR should support the SRC's request for securing representation from the New York State Department of Labor's (DOL) Statewide Workforce Investment Board (SWIB).

ACCES-VR Response: ACCES-VR formally communicated with the SWIB Chairperson, Mr. Richard Calo of IBM, and requested the SRC DOL representative, raise this request for representation with DOL management. The ACCES-VR Deputy Commissioner will continue to pursue SWIB representation through the NYS DOL.

SRC Recommendations: Other state agency partners should be invited to SRC to give presentations on their employment agendas.

ACCES-VR Response: During the reporting year, representatives from the Office of People with Developmental Disabilities presented on their Employment First initiative. The DOL presented on their web-based employment programs (e.g., Job Zone and Job Programs Search). The Office of Mental Health presented on the Personal Recovery Oriented Services (PROS) and provided several updates on the activities of the Medicaid Infrastructure Grant. ACCES-VR remains committed to utilizing the SRC quarterly meetings as an important mechanism to promote interagency communication and collaboration.

SRC Reporting

SRC Recommendation: SRC recommended that the FFY 2009 Annual Report be sent formally to the Board of Regents (BOR) on December 31, 2009 with a letter requesting that it be a discussion or information item at the BOR February or March meeting.

ACCES-VR Response: ACCES-VR agreed with the intent of the recommendation and the 2009 SRC annual report was shared with the BOR though the BOR’s schedule did not allow the Regents to review the report at the February or March meeting. ACCES-VR did commit to getting the FFY 2010 Annual Report on the Regents agenda during 2011.

SRC Recommendation: SRC recommended that the submission of the FFY 2010 Annual Report to the Rehabilitation Services Administration (RSA) be delayed until the end of the year outcome data could be incorporated. The SRC recommended the FFY 2010 Annual Report be formally distributed to the Board of Regents at one of its spring 2011 meetings.

ACCES-VR Response: ACCES-VR recognizes SRC’s interest in delaying submission of the SRC annual report until VR data from the reporting year is finalized and available for publication in the report. ACCES-VR and the SRC are obligated to comply with the RSA reporting deadline of 90 days following the end of the federal fiscal year (e.g., December 31, 2010). ACCES-VR will make preliminary data available to assist with meeting the federal SRC annual reporting requirements.

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