Significance of Disability Training Questions
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DATE: May 19, 2003
Many questions were raised during the recent training on the new "Significance of Disability" policy and procedures. In developing the response to those questions it appeared to be necessary to provide a general clarification of the relationship between (a) the services the consumer needs to achieve the employment goal and (b) the services that are needed to reduce the impact the consumer's disability on the limitations in functional capacity. Only those services related to (b) are used to determine the Significance of Disability (SD) level.
As noted in Procedure Section II B. Multiple Rehabilitation Services Required to Reduce Impact of Limitations on Employment: "When determining Significance of Disability, a counselor needs to determine what services are necessary to reduce the impact of functional limitation on employability."
Example 1: A consumer who is deaf.
The projected service needs may include the following:
- Training (for goal)
- Interpreter Services
- Note Taking
- Remedial Educational Services
In determining SD the question is which of these services will directly impact the consumer's limitations as they relate to Functional Capacity categories. In this example the response would be:
- Interpreter Services - As a deaf individual this service is needed to address Communication issues.
- Note Taking - Same as above.
- Remedial Education Services - Possibly, if it is determined that the consumer's disability prevented him or her from achieving academically in school and remediation is needed to address issues related to functional capacity categories, i.e., Work Skills or Self Direction.
Training, transportation, books or a computer, unless its a rehabilitation technology service, would not be considered because they are needed to train for the goal and are not directly related to the limitations to functional capacities.
Example 2: A consumer who is being considered for Supported Employment Services.
The projected services may include the following:
- Situational Assessment related to development of the Individualized Plan for Employment;
- Mobility Training;
- Job Coaching, as a form of specialized training; and
- Job Related services, including as examples, job search, placement, retention and follow along services of a job coach or job developer.
In determining SD the question is which of these services will directly impact the limitations the consumer has with respect to functional capacities. In this example the response would be:
- Situational Assessment -The consumer will need an assessment to address Communication, Work Tolerance, Work Skills, etc. The particular Functional Capacities to be assessed will vary from one individual to another.
- Mobility - The consumer is only capable of route travel. he must be trained to travel the direct route from home to work-site.
- Job Coaching - Specialized training to assist consumer in as an example, developing Work Skills. The reason for job coaching services may vary from one individual to another.
- Job Related Services - Job search, placement, retention and follow up services of a job coach or job developer may be needed to address limitations in one or more Functional Capacity areas.
There were additional questions regarding consumers receiving Supported Employment. The counselor will need to complete a comprehensive assessment which will among other things consider the individual services needed by the consumer to reduce the impact of the limitations on Functional Capacities. The comprehensive assessment should also consider the individual's need for long term job retention and follow along services. If in the judgment of the counselor these services will be needed over an extended period of time of six months or more, then the duration requirement for Most Significant Disability will be satisfied.
It is believed that the previous examples will help in clarifying the steps for determining Significance of Disability. The following are the specific questions that were raised during the training.
|1. Please give more examples of generic vs. specialized training for the disabled. For example, does NTID or Gallaudet qualify as specialized training? Does vocational training that takes place at a Community Rehabilitation Program, e.g. computer programmer training at RRC in Rochester qualify? Would training other than PAT that takes place in a CRP be considered specialize?||In determining Significance of Disability the issue is whether the service is being provided to reduce the impact of the disability. Where (location) or by whom the training is being provided is not a consideration for SD determination.|
|2. Would a work survival skills development program (pre-vocational) at a CRP be considered generic or specialized training?||If the work survival skills training is being provided to reduce the impact of a functional limitation, then the answer is yes. For example, a consumer with a history of Mental Illness and a sporadic work history may need this training to address issues related to Work Tolerance. The fact that the training is provided via a CRP is not related to the analysis.|
|3. If vocational training at a CRP is considered specialized, but training toward the same goal in "school" is considered generic, aren't we encouraging segregation?||No. The issue is not the location or the entity that is providing the training. Any specialized training that is needed as a result of the individual's disability related limitations could be considered when determining SD.|
|4. Why wouldn't college training count as a major service if an individual is SD or Most SD and needs advanced training to achieve an employment outcome?||College training that is required of all individuals, regardless of disability, to work in the selected professional field is not considered when determining SD. The service is needed because it is required to meet the minimum qualifications to work in the chosen field, not as a disability-related service. Everyone must take the courses. The references to "major vocational rehabilitation services" has been removed from the SD Procedures. The term "disability-related services" has been substituted.|
|5. What is a "Transition Service" that would be countable as a major service?||"Transition service," was removed from list of disability related services in SD procedures. When working with a student transitioning from high school the counselor will consider the individual services that will reduce the impact of the limitations on the individual's Functional Capacities. "Transition services" may include one or more disability related services.|
|6. Please explain appropriate use of Functional Limitations in the Functional Capacity area of "Work Skills" (especially with regard to substance abuse disabilities)||We are not clear as to the question.|
|7. Please provide example of "ongoing assessments other than for eligibility."||As noted in the example regarding the individual being considered for Supported Employment, a Situational Assessment that is designed to assist with the development of the IPE, rather than to establish eligibility, can be used as an "ongoing assessment." An assessment may be used at different points in the process. The purpose may be eligibility determination or IPE development.|
|8. Please provide examples of "job related services." Would job search or resume services secured from an employment agency be considered "generic" or would they count?||A list of job related services are included in the SD Procedures, Section IIB. Generally, job search or resume services could be considered "generic" services, however in situations in which an individual requires this service because the limitations of their disability prevents them from securing a job without specialized services then the service can be considered specialized and used in determining SD. An example of this situation is job development as part of Supported Employment Services.|
|9. Supported Employment: What if the range of Supported Employment services does not last for 6 months? For example, cases that are re-referred for a new placement?||When the Comprehensive Assessment indicates the individual will need Supported Employment Services it can be regarded that the individual will require job retention and follow along services for an extended period of time. Therefore in these cases the timeframe will be met. Section C of the procedures, Duration of Services for an Extended Period of Time, has been changed. The measure of time from status 10 to status 22 has been modified to: "The time to be considered begins at eligibility determination and will continue for as long as it is anticipated that the individual will require and receive disability-related services, up to the projected Status 26 closure date."|
|10. The question concerns Supported Employment as one service and the need to code consumers most significantly disabled to qualify for this service. During the training we were told that Supported Employment could only be counted as one service.||Supported Employment Services can best be thought of as a package of services, that as per the example provided earlier, can include several disability-related services. The comprehensive assessment does not assume that the individual requires Supported Employment Services. Rather, once the consumer's needs for disability related services are identified, it may be concluded that Supported Employment Services will be required by the consumer to achieve an employment outcome.|
|11. Why would we not count extended services or follow-along services as major services for someone who needs SE? In the past, we could.||Section IIC - Duration of Services for an extended period of time has been revised in procedures. These services can now be considered in determining the level of Significance of Disability.|
|12. Must someone requesting 55A or 55B certification be classified as Most SD?||Representatives from Civil Service were provided an orientation of the new SD policy. Consumers being considered for 55A or 55B must be classified as being Significantly Disabled.|
|13. Can services that are being provided by others, where there is no cost to ACCES-VR, be counted towards the multiple service requirement? Our understanding is that it should be recorded on the service page of the IPE.||Any vocational rehabilitation service that meets the definition of disability related services is to be considered. These services should be specified on the IPE. An enhancement to CaMS is currently under development to facilitate this. In the mean time this information can be recorded under the Criteria to Evaluate Progress.|
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