Questions and Answers on College and University Training

Q1:  Can you clarify how to apply excess PELL to the required textbook costs?

Pell and other comparable benefits are not applied to the cost of books.  This recognizes that individuals incur additional personal expenses related to college study that are not covered by ACCES-VR.  This has been in procedures since the college policy revisions in 2003.  However, additional clarification is provided now since books are no longer contingent on economic need. 

Q2:  How will District Office Managers and ACCES-VR Central Office resolve local disputes with colleges over providing necessary disability-related support services?

The Resolving Disagreements Section (page 14) of the College Policy states:

If both parties cannot reach agreement within 15 calendar days the District Office Manager should attempt to resolve the disagreement with the college ADA Compliance Officer.

Additional steps for this process are being developed with SUNY and CUNY.  The process will be reviewed with District Office Managers when final.

Q3.  What are additional reasonable standards (other than Transportation Policy limits) for DO’s to abide by when establishing local standards for allowable commuting to college? How do we address cost effectiveness issues when Room & Board at the college would be cheaper?

Commuting standards are to beestablished locally based on transportation resources available. We also decoupled commuting transportation to college from Room & Board expenses. Cost-effectiveness does not apply here – they are two separate services and a comparison no longer applies. District Office Managers will develop local standards in consultation with their local management teams.

Q4.  If overpayment has been made to the consumer for college costs, who other than the VRC can assist with retrieving outstanding monies owed to ACCES-VR? Is there a NYSED Fiscal Department role in this when the local office efforts are not successful?

At this time, there are no NYSED Fiscal Department resources for assisting DO’s with retrieving outstanding monies owed to ACCES-VR. In accordance with College Policy, any overpayment can be applied to future services by the ACCES-VR counselor. DOMs can assign staff to support this function as appropriate.

Q5.  Can we look at raising the $4,815 dollar limit for Cost Effective Training? Also, now that purchasing required books and related materials are not an economic need service – does it make sense to include these costs in the dollar cap limit?

We will look at both of these concerns when ACCES-VR reviews the Consumer Participation in the Cost of Services Policy.

Q6.  Can we locally waive 2007 Summer School costs up to the new college policy limits?

Yes, this is covered in the June 2006 College and University Training Procedures in the Waiver Section related to part-time study.

Q7.  How do we define assistive technology that is not contingent on economic need as compared to rehabilitation technology that is?

The policy allows the purchase of low cost ($300 – $400) assistive technology devices regardless of economic need when required for consumers to make use of special adaptive books and materials. If assistive technology is required for other than accessing books and related materials, such as for classroom use or to utilize computers - this should be covered under our Rehabilitation Technology Services and is contingent on economic need.

Q8.  If a college program of study requires purchasing certain tools and required equipment in order to participate – shouldn’t this be considered like books and other required materials and also be non economic need? How about uniforms?

Tools, equipment and uniforms are not considered as required books and related training materials and therefore are based on economic need. For clothing, use  guidance in POL-05-01 dated April 18, 2005.

Q9.  Is Landmark College one of the schools that fall under “Special Support Services Schools”?

No. It is a special college for LD students and is not one of the previously approved colleges allowing ACCES-VR payment for learning disability services, i.e. Manhattan, Mercy, Iona and Hofstra Colleges.

Q10.  Would we pay for computer access at a computer café?

No.

Q11.  What is ACCES-VR’s participation in the 24-college credit hour GED® program within a college setting?

The New York State High School Equivalency Diploma Based on Earned College Credit is a NYSED program that is awarded to candidates who have completed 24 credits (or its equivalent) as a recognized candidate for a degree or a certificate at an approved institution. http://www.acces.nysed.gov/ged/docs/attch-j.doc.

If the consumer meets the college’s admission requirements or otherwise demonstrates the ability to academically succeed in college level work (federal ability to benefit standard assessed by the college and curriculum eligibility for Pell funding), ACCES-VR could support the person in college study as part of an IPE toward a specific employment goal that requires a college degree.  The ACCES-VR Counselor should carefully assess whether the individual requires college study to achieve an employment goal and whether courses completed under the 24-college credit hour GED® program can be applied towards their desired college program of study. Otherwise, remediation for basic academic skills should be accomplished before college admission to avoid prematurely exhausting TAP, Pell or ACCES-VR length of training limits. ACCES-VR Counselor consultation with the “College Disability Service Provider” is highly recommended when accessing these circumstances.

Q12.  Can graduate school be considered if it will further a consumer’s progress in his or her profession?

The new college policy has not changed the criteria for graduate school training. It must be required to enable a consumer to get started in a career or to maintain the job. See new College Policy Graduate School Section on page 16:

• The consumer requires graduate training in order to enter the profession, which is an agreed upon employment goal on the IPE, or
• The significance of disability limits the consumer’s ability to function in an entry-level job while simultaneously completing additional training at the graduate level required to maintain the job.

In situations when a person is under employed or is applying for additional services while working, see Eligibility Procedures section: Criteria for Determining Eligibility. We cannot provide Graduate School training under post-employment services (PES), because this level of training does not meet the “limited scope and duration” condition for PES.

Q13.  There is a trend in job placement that requires job applicants to have Internet access.  Are we addressing this in our policy?

This question does not relate to the new college policy.  For job placement, there should be public resources the consumer can utilize. (I.e. ACCES-VR District Offices, one-stop centers, public libraries or other available DOL employment centers)

Q14.  Does student loan default apply to cost-effective training?

Student loan default requirements apply to any postsecondary program that is eligible for Pell funds. See Defaulted Student Loans Section on page 14 of the new college policy:

ACCES-VR is prohibited from paying for any training or related services at an institution of higher education for an individual who owes a refund on a grant or is in default of a student loan unless the individual makes maximum effort to resolve the default.

Q15.  What is the VRC’s role in reviewing the VES 845 (ACCES-VR Contribution Calculation Work Sheet) and the application of comparable benefits when this form goes directly to the Finance Office from the college?

Most local ACCES-VR financial offices request input from the ACCES-VR Vocational Rehabilitation Counselor if there are any questions. If the ACCES-VR Counselor has a question or if they want aid applied a certain way, they should inform the college and their local ACCES-VR finance office.

Q16.  How will ACCES-VR CO update colleges and college bookstores on our new college policy?

We have requested representatives on our work group who are part of the SUNY and Statewide College Financial Aid Officer’s Association – to disseminate our new College and University Training Policy and Procedure. Local DOMs and/or their designees are also reaching out to colleges in their region and the Student Disability Service Coordinators.

Q17.  How should we handle when a college requires a student to buy “their” computer rather than one that is most cost effective and can still meet the college computer standards and also meet the student’s needs?

Review the college’s protocol related to the purchase. Possible benefits may include the availability for on site support or special wireless software. Having those resources available (and sometimes free to the students) may be reason enough to buy what the college requires. Other field feedback confirms that most computers offered through the college are very reasonably priced, due to volume discounts.

Q18.  As some full time CUNY graduate programs are only 9 credit hours, how do we handle ACCES-VR sponsorship?

If this is confirmed in writing by the college, then they can be treated as full-time.

Q19.  Is it 15 calendar days for dispute resolution time limit?

Yes.

Q20.  Are ACCES-VR sponsored tutoring services available for non-college training?

Yes.

Q21.  If someone gets SSI, do the monies they receive count towards room and board?

No.

Q22.  Do the semesters that a consumer pays for (or if there are no costs to ACCES-VR because of financial aid) count toward time limit parameters?

It is pro-rated for only those previous college credits (with or without ACCES-VR support) that can be applied towards the current agreed upon course of study. The new college policy did not alter previous guidance provided in PRO-04-01, Caps on Rates and Duration of Services, dated November 2, 2004:

Training at a College or University - ACCES-VR will provide financial contribution for up to one semester in addition to each required academic year to complete required course work. A maximum of two additional semesters will be allowed to complete a two-year program, and a maximum of four additional semesters will be allowed to complete a four-year program if needed. These maximum allowances include all part-time training and can be pro-rated for students who have completed coursework toward the degree. These maximum time frames are cumulative and include any change in school, major course of study and case re-opening after partial completion, unless a significant change in the individual’s situation provides good cause for additional time.

Note:  Time limits may be waived at the local District Office level.

Q23.  Do we divide the annual SUNY/CUNY tuition rate by 3 for students attending a trimester private program, or do we authorize the tuition at 3 semesters at the SUNY/CUNY semester rate?

We would divide the annual SUNY/CUNY Tuition rate by 3 for each trimester.

Q24.  Does the new college policy reinstate our ability to reimburse the student for round trip travel to the campus each semester?

No. The new college policy Transportation Section on page 12 states:

When the student will be living away from home, transportation will not be authorized for travel to and from college.

Q25.  When considering the provision of Internet services, can ACCES-VR reimburse the consumer directly for the most cost-effective service (dial-up) to be applied toward the higher cost service that the consumer purchases (i.e. high speed cable)?

Yes.  However, there may be potential income tax implications if we incorrectly make consumers into “vendors”.  Setting up a consumer as a vendor must be done in accordance with PRO-15-02. This has a cap of $300 for the lifetime of the case and the ACCES-VR VR Counselor must document that there is not a vendor for this service that will accept a ACCES-VR authorization.

Q26.  What can ACCES-VR Central Office do to promote statewide, our ability to get local Internet service vendors to accept our authorizations?

We will be looking into this and updates will be provided at DO Managers Meetings. Right now, there are a number of resources available for Internet access through contracts developed by OGS.  

The Cable Internet Access Contract with Time Warner can be found at:
http://www.ogs.state.ny.us/purchase/snt/awardnotes/7701500969can.htm

The Dial Up Internet Access Contract with AT&T can be found at:
http://www.ogs.state.ny.us/purchase/snt/awardnotes/770154395can.htm

Q27.  What is ACCES-VR’s contribution for a college on a trimester that grants an AAS Degree in 18 months?

Treat as individual trimesters as in question #23.

Q28.  Are out-of-state, State Schools, considered as private colleges for our cost contribution?

Yes.   Use the maximum published SUNY tuition rates less comparable benefits. Out of State “State” colleges, like a private college, will require Central Office Waiver Committee approval when exceeding the SUNY rate. 

Q29.  Can you clarify how Cost Effective Training provisions relate to meeting economic need standards for college training programs?

The new College Policy under Cost Effective Training on page 16 states:

If a non-degree course of study at a college will be completed within one year, ACCES-VR’s cost-effective services exception can be applied for individuals who do not meet economic need criteria.

Consumer Participation in the Costs of Services Policy, also amended in 2007 states:
The following services are provided by ACCES-VR without considering a person's financial resources: cost-effective training.
This indicates that an economic need statement is not required if this is the only service to be provided. The new college policy should be interpreted in a way that supports this statement.  An economic need determination may still be required for other related VR services provided to the consumer.

Q30:  How much should we be authorizing to part-time students for books?

Required textbooks and materials, whether full-time or part-time, will be authorized up to the SUNY published rate, currently $550 per semester.

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