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Comments for WIOA NPRM

June 15, 2015

June 15, 2015 - Maine’s voice heard in Washington D.C. Please take the time to read through a letter from our Executive Director, Jim Phipps, to the Commissioner of Rehabilitation Services Administration, Honorable Janet LaBreck.


Honorable Janet LaBreck
Commissioner, Rehabilitation Services Administration
U.S. Department of Education
400 Maryland Ave. SW, RM 5086
Washington, DC  20202

RE:      Comments for WIOA NPRM
Docket Number: ED-2015-OSERS-OOO1
RIN: 1820-AB70

Dear Commissioner LaBreck:

The Iris Network appreciates the opportunity to offer comments in the above referenced rule making process.  The Iris Network is a nonprofit 501(c)(3) vision rehabilitation agency based in Portland, Maine.  We have served people experiencing vision loss and blindness throughout the State of Maine and neighboring New England states since being founded in 1905.  As its President and Executive Director, I appreciate the opportunity to provide the following comments on the NPRM covering Parts 361, 363, and 397 of the proposed regulations. 

By way of background, early in the 20th century, the founder of The Iris Network, William J. Ryan (who was visually impaired himself), traveled across the State of Maine as an almanac salesman.  He saw others who were blind kept at home and isolated from society.  Mr. Ryan had a vision.  He articulated it as the ability of an individual who was blind to "stand up at the workbench and earn his daily bread." 

William J. Ryan worked with the Maine Fraternal Association of the Blind (now the Maine Chapter of the American Council of the Blind) to organize the Maine Institution for the Blind (now The Iris Network) as a Maine nonprofit corporation in 1905.  The purpose of the organization was to provide vocational training and jobs for people who were blind.  As a result of his determination and persistence -- with fundraising help from Helen Keller and with Joshua Chamberlain leading the Board of Directors -- the William J. Ryan building opened as a 16,800 square foot factory facility employing blind workers in 1908. 

Over the last 50+ years, the mission of the organization has shifted away from direct employment of people who are blind or visually impaired.  The Iris Network now provides primary vision rehabilitation and vocational skills training to prepare clients to work for private businesses in competitive employment.  

For the last 20 years, The Iris Network has provided primary vision rehabilitation services in Maine through a community-based itinerant service delivery system.  Under the itinerant model, Vision Rehabilitation Therapists and Orientation and Mobility Specialists travel throughout the state to provide services to transition-age students, working age adults and older individuals with blindness and low vision on a one-on-one basis.  Although this approach is effective, it can often take two years or more for a newly blinded individual to learn all the skills needed to compensate for vision loss.

Consequently, The Ryan Building is now undergoing a $1,690,000 renovation ($1,414,250 of which was funded by RSA in FFY2014 as an Establishment Project).  The newly renovated facility will house an intensive vocational rehabilitation program being launched in September of 2015 for clients eligible for vocational rehabilitation services.

I trust that the foregoing background provides a useful context for understanding the following specific comments on particular elements of the proposed regulations.  More information about The Iris Network and its programs and services can be found by visiting our website at www.theiris.org.  Our specific comments follow:

Section 361.5(c)(9)

The newly added definition of Competitive Integrated Employment merges together the two previous existing regulatory definitions of “Competitive Employment” and “Integrated Setting.” In the WIOA statute, the definition includes “advancement” as one of the three means to determine such a setting, along with “competitive wages” and “integration.”  The statute does not, however, expand beyond mention that a job must include the same opportunities for advancement. The definition further explains that integration focuses on the “work unit,” so that even if someone is interacting with non-disabled individuals, such as in a customer service call center setting, integration will only focus on the work unit.

COMMENT:

It seems to go against the nature of WIOA, to deny individuals opportunity for advancement or higher wages (two of the three identifiers) if a setting is deemed non-integrated. There should be an exception made for determining a work setting as non-integrated if an individual chooses such a setting because the opportunity to receive higher wages and more opportunities for professional growth and advancement will result in greater community integration and upward mobility. 

Section 361.5(c)(15)

In the “Employment Outcome” definition, the proposed regulations remove “Uncompensated outcomes” as noted in the explanation of the revised regulation. This includes both “Homemaker” and “unpaid family worker” outcomes. While RSA reports that only 0.8% of outcomes utilize this pathway for individuals with disabilities, over 10% of outcomes among individuals served through Designated State Units for the blind will be adversely impacted.

COMMENT:

In the Preamble to the NPRM, RSA discusses a policy decision to amend the regulatory definition of “employment outcome” to include only compensated outcomes.  This would eliminate uncompensated outcomes including both homemaker closures and closures for individuals in unpaid family work.  RSA cites changes that the Amendments incorporated into Sec. 100(a), Findings, Purpose, Policy, of the Rehabilitation Act of 1973, as amended, as justification for this policy decision.  The Amendments include language emphasizing competitive integrated employment and economic self-sufficiency for individuals with disabilities served under the VR and SE programs. 

While this policy decision may be supported by the Amendments, it is not mandated by the 2014 Amendments and is clearly a policy decision made by RSA.  In justification for this policy decision, RSA acknowledges that the percentage of homemaker closures is higher in agencies serving only blind and visually impaired individuals.  RSA-911 data for FYs 2011-2013 indicates that, for agencies serving only blind and visually impaired individuals, between 10.7% and 12.1% of successful closures were homemakers or unpaid family workers during those fiscal years.  For individuals who are blind or visually impaired served by combined agencies, successful closures as homemakers or unpaid family workers were 27.3% to 30.2% during that same time period.  The DSU for the State of Maine reports that in certain regions of the state, 80% of clients with blindness or visual impairment choose the homemaker outcome.    

It is clear that this policy decision will have a disproportionate impact on services to individuals who are blind or visually impaired– whether those individuals are served by separate blindness agencies or by combined agencies.  Likewise, this policy decision will impact individuals who are blind or visually impaired more than any other group.

The proposed removal of “uncompensated outcomes” was not mandated in statute, but rather at the Department’s discretion. If implemented, individuals who are blind would no longer be allowed to choose the homemaker outcome, which is often chosen by working-age clients in order to regain the confidence and skills needed in order to become independent before choosing to return to work.  Although RSA gives instructions on how to refer these individuals to other government or community service providers if the change were to be implemented, these alternate providers lack both the specific vision rehabilitation professional skills, and adequate financial resources, to provide primary vision rehabilitation services for all of the clients needing these services. 

The Iris Network strongly urges that this proposed change be reconsidered and reversed because there is a clear disproportionate impact on individuals who are blind, without necessary assurance that critical and unique services will still be available for these consumers. We recommend striking this revision. If not, then further guidance is necessary to assure these individuals will not be isolated and shut out of vital rehabilitation services.

The Iris Network suggests that the reason why uncompensated outcomes are disproportionately higher in blindness agencies than for agencies serving people with other disabilities is due to the fact that blindness rehabilitation is not provided as part of the health care system.  Unlike people with physical disabilities who receive extensive rehabilitation services reimbursed by Medicare and private health insurance as part of the health care delivery system before they seek vocational rehabilitation, people experiencing vision loss do not have access to primary rehabilitation including vision rehabilitation therapy and related services such as orientation and mobility before they access vocational rehabilitation services.  This is because these blindness specific primary rehabilitation services  are not reimbursable by Medicare and private health insurance.  Consequently, blindness agencies must deliver primary rehabilitation before they can effectively offer vocational rehabilitation services to their clients. 

In fact, one of the most difficult aspects of losing one’s vision is the process of adjusting to a new life as a capable blind or visually impaired person.  Most people experiencing vision loss feel a loss of control and self-determination, as well as a loss of confidence, self-worth, and purpose.  Because blindness and severe vision impairment is a low incidence disability and because vision rehabilitation is not provided as part of the health care system, those experiencing vision loss without rapid access to vision rehabilitation often become very isolated and easily subscribe to common misconceptions about blind people being helpless and incapable. 

Consequently, many clients entering the blindness rehabilitation system are not yet ready to consider vocational opportunities.  They initially reject work as an outcome, preferring instead to focus on regaining independence with activities of daily living.  While independent accomplishment of life’s daily tasks is fundamental to vocational readiness and ultimate employment, many clients reject employment outcomes at first.  Many, however, do return to work after initially being closed as homemakers once they gain success and confidence as independently functioning members of their communities.

The proposed regulations suggest that people experiencing severe vision loss and blindness who are not ready for vocational rehabilitation seek primary rehabilitation services through centers for independent living.  This proposed alternative to the current system is not appropriate because centers for independent living lack both the ability to deliver specific vision rehabilitation professional services, and the financial resources necessary to provide primary vision rehabilitation services.  If Medicare reimbursement were available for services provided by Vision Rehabilitation Therapists and Orientation and Mobility Specialists at appropriate rates, then the proposed elimination of the homemaker outcome might be feasible, but until then, this outcome must remain a part of the vocational rehabilitation system.

Furthermore, elimination of the homemaker closure excludes many clients from vocational rehabilitation who work as uncompensated primary caregivers for disabled spouses, parents or children.  The provision of these forms of uncompensated work is highly valued as a matter of public policy and should continue to be supported by the federal vocational rehabilitation system because this uncompensated work allows many Americans to avoid unnecessary institutionalization in costly long-term care facilities.  Providing vocational rehabilitation to consumers who are providing unpaid primary care to members of their family is a cost effective way to avoid costly long-term care for those family-members at great public expense.

Additionally, a number of states, including Maine, have adopted state legislation known as “Employment First.”  This legislation establishes, as a matter of state law, the doctrine that employment must be considered as the first and foremost option for people receiving state services.  As a result, before services that do not result in employment can be provided to consumers, a finding must be made that (a) employment options were explained to the consumer and (b) the consumer made an informed choice to pursue non-employment alternatives to compensated work.  If it is thought that uncompensated outcomes are too easily accepted by DSUs, then a doctrine such as “Employment First” could be built into the rules before an uncompensated outcome can be elected by the consumer. 

For all of the foregoing reasons, The Iris Network strongly opposes removal of “homemakers” and “unpaid family workers” as successful employment outcomes and requests that this policy change be reconsidered and reversed.  Specifically, we recommend that homemaker and unpaid family workers remain successful employment outcomes under the State VR Services Program because, otherwise there will be a disproportionate impact on the availability of rehabilitation services for people who are blind or significantly visually impaired.  This is due, in large part, to the fact that primary vision rehabilitation is unavailable through the health care system.  Also, the unpaid family worker outcome should be retained because this form of unpaid work is needed in order to avoid unnecessary institutionalization of the family member receiving uncompensated care.  Such unnecessary institutionalization comes at an unaffordable price to our society. 

Additionally, the statutory definition of “employment outcome” in section 7(11) of the Act, allows the Secretary of Education to identify other appropriate vocational outcomes.  Given this provision, The Iris Network recommends that the Secretary continue to recognize “homemaker” and “unpaid family worker” as appropriate vocational outcomes of the State VR Services Program.

RSA also requests comments on whether a transition period of six months following the effective date of the final regulations is needed to allow State VR agencies time to implement this change.  If RSA retains this policy decision in the final regulations, then The Iris Network recommends that a longer transition period of at least two years be allowed for those individuals who may already be receiving VR services towards an employment goal of homemaker or unpaid family worker.  This longer transition period is recommended because it may take two years or more for people being served under the rules currently in effect to complete their individualized plans for employment (“IPE”).  These consumers should have the right to complete their IPEs without being adversely impacted by a rule change that becomes effective after their IPEs were adopted.

Furthermore, The Iris Network points out that some DSUs, including Maine’s state blindness agency, have entered into long-term (20 year) agreements with Community Rehabilitation Providers such as The Iris Network that limit the use of RSA funded facilities (i.e. “establishment projects”) to people eligible for vocational rehabilitation services.  For arrangements predating any change in the eligibility rules, the eligibility regulations in effect when the agreements were negotiated will control.  Therefore, those agreements may run for 20 years following any change in the rules that are now in effect.  The Iris Network specifically requests that existing contractual arrangements be excluded from the application of the new rules.

§361.5(c)(51)

The proposed definition of “student with a disability” in §361.5(c)(51) basically repeats the statutory definition of “student with a disability” included in Section 7(37) of the Act.  The proposed definition includes an age range and states that the student is either receiving special education services or is an individual with a disability under Section 504.  In the explanatory notes about this proposed definition, RSA states that it intends this definition to apply only to students currently in IDEA-funded special education or to students in secondary school under what is commonly called a Section 504 plan.  The preamble states:

“However, it is important to note that we have interpreted a student with a disability, given the plain meaning of the statutory definition, as not including an individual with a disability in postsecondary education.”

 

In this statement, RSA clearly indicates that other interpretations of the statutory definition of “student with a disability” are possible. 

COMMENT:

The Iris Network recommends that a broader interpretation of “student with a disability” is needed for the purposes of the provision of pre-employment transition services.  A broader interpretation would be beneficial because some DSUs (especially agencies serving only blind or visually impaired individuals) will find it difficult to meet the 15% set-aside for pre-employment transition services to students with disabilities within the more narrow interpretation that RSA is proposing. 

The broader definition should include individuals with disabilities (as defined for purposes of Section 504 of the Act – not just those under Section 504 education plans) who are still in school – either at the secondary or the post-secondary level and meet the applicable age-range in that state.  The Iris Network also recommends that the definition be broadened to encompass students who are home-schooled, students in GED classes, students in ESL classes, students in community college or vocational technical school classes, and even students in other post-secondary school situations as long as the student meets the definition of “individual with a disability” for Section 504 purposes and is below the age limit applicable in the State.  Furthermore, The Iris Network recommends that an individual should meet this definition at the onset of the provision of pre-employment transition services (see further comments below on this issue).

§361.18

The 2014 WIOA Amendments made a change to the requirements that a DSU maintain a comprehensive system of personnel development.  The new language in section 101(a)(7) of the Act describes the education and experience requirements that would ensure that state VR personnel have a 21st century understanding of the labor market and the employment needs of individuals with disabilities.  In the proposed regulations, RSA has incorporated the statutory change regarding personnel standards.

COMMENT:

Both the statute and the proposed regulations maintain the language about the establishment and maintenance of personnel standards that are consistent with any national or state approved or recognized certification, licensing, registration, or other comparable requirements that apply to a particular profession.  Therefore, The Iris Network believes that the new language contained in the 2014 Amendments regarding the education and experience requirements that would allow for the attainment of a baccalaureate degree plus one year of relevant job experience, do not apply to the category of vocational rehabilitation counselor.  This is based on the acknowledged fact that a national certification exists for this profession (Certified Rehabilitation Counselor), and that many states have counselor licensure laws.  Both the national certification and state licensure laws require a Master’s degree as the minimum qualification for a vocational rehabilitation counselor. 

National certification and state licensure laws apply to the profession of VR counselor.  Therefore, proposed §361.18(c)(1)(ii)(A) should not apply to this major category of personnel in DSUs.  Because there was no legislative report accompanying the WIOA Amendments, RSA cannot be certain that Congress intended that the education and experience requirements in section 101(a)(7)(B)(ii) apply to vocational rehabilitation counselors.

Because RSA is also seeking comments on examples of what it means “that the personnel have a 21st century understanding of the evolving labor force and the needs of individuals with disabilities,” The Iris Network points out that the GAO recently did a study of knowledge gaps found in vocational rehabilitation counselors employed by the Veterans’ Administration.  RSA should look to that report for additional areas to add to this listing of examples.  Some additions could include the following:

  • In-depth knowledge of labor market trends
  • Familiarity with BLS data and the DOT and O*Net occupational systems
  • Knowledge of testing and assessment strategies
  • Knowledge of job accommodations
  • Training in the ADA and other employment nondiscrimination laws
  • Understanding of vocational implications of various disabilities, including TBI, PTSD, autism and mental health issues as well as blindness
  • Employment plan formulation and coordination of resources
  • Knowledge of the implication of Social Security work incentives and the Ticket to Work
  • Familiarity with the broad range of disability programs available in the state and local area, including independent living programs

Because The Iris Network is particularly concerned with services to individuals who are blind or visually impaired, we suggest that this listing also include examples of skills needed in serving this population.  These skills should include orientation and mobility training, Braille instruction and knowledge of technology and devices that can assist in mobility and communication for individuals who are blind or visually impaired.

Section 361.18(c)(1)(ii)

In the section covering Comprehensive Systems for Personnel Development (CSPD), the standard for qualifications is revised to include work experience, either paid or unpaid, in a series of settings encompassing disability rehabilitation (i.e.: social work, centers for independent living, etc.).

COMMENT:

The variety of unique and complex skills necessary to adequately provide services and supports to individuals who are blind (such as braille instruction, assistive technology training, or orientation & mobility) require significant training and certification. Without such specialized skills, individuals who are blind or visually impaired run the risk of being greatly underserved and this could serve as a major impediment to full independence and employment.  

For this reason, we recommend adding a new sub-section (c), which states:

(C) A compliment of work experience, in addition to specialized training or certification through either advanced higher education or through a legitimately recognized association that provides specialized training when working specifically with individuals who possess unique barriers to independence and require unique training, such as individuals who are blind.

§361.36

The Iris Network supports changes in this section that incorporate the new statutory provision in section 101(a)(5) of the Act.  This new provision allows a DSU to serve an eligible individual, even if that individual does not meet the order of selection in that state, if the individual requires a specific service or equipment in order to maintain employment.

COMMENT:

Although not addressed in the NPRM, The Iris Network believes further guidance is needed concerning the impact of the new service requirements for students with disabilities who may or may not be eligible for VR services.  Given that students who have not been found eligible for VR services can receive pre-employment transition services, this in effect supersedes the order of selection requirements.  Students with disabilities who do apply for and are found eligible for VR services may then be placed on a waiting list should they not fit into a priority category in a state’s order of selection.  This seems unfair and not what Congress intended when it established the new category for pre-employment transition services.

In another significant way, the 15% set-aside for pre-employment transition services may force DSUs to go on an order of selection or close categories under an existing order due to limited funds available for the other individuals seeking and receiving VR services in a state.   The 15% reservation is from existing funds that are currently used to serve all eligible individuals of the VR agency.  By removing this funding from overall case services and program administration activities, and by further defining the allowable use to such a narrow age range of individuals, there is a direct impact on the available case service funding for the remainder of the VR population.

The Iris Network serves an aging population based upon the overall demographic for the onset of blindness. It is not uncommon to find transition age youth to represent no more than 15% of the client population. Diverting funds from other eligible individuals to serve such a narrowly defined population will likely result in insufficient funds to serve all other eligible individuals while at the same time leaving underutilized funding from the 15% reserve that cannot be accessed for any other purpose, even if good faith efforts are made to first satisfy the allowable use of the reserve funding.

Section 361.48(a)

In this section, RSA establishes that 15% of funding shall be set aside for Pre-Employment Transition Services (PETS) of youth and students with disabilities.  The term “youth and students with disabilities” is defined as applicable to individuals between 14 – 24 years old.

COMMENT:

While some states may have 15% of youth and students with blindness currently served through the VR system, the percentage of adults between the ages of 24 – 64 comprises the overwhelming majority of individuals experiencing vision loss who are eligible for employment services and supports. This gap will continue to grow over the next decade, as prevalence continues to increase as the Baby Boomer generation continues to move toward retirement age.

Many visual impairments (such as diabetic retinopathy, glaucoma, and trauma) are more frequent among 40 – 50 year olds. Many of these individuals will not yet qualify for independent living services under the Older Individuals with Blindness (OIB) Program (34 CFR 367). Such a demand could create a scarcity of resources available for individuals who are blind.

Therefore, The Iris Network recommends that RSA provide exemptions for this set-aside (or any other population subject to disproportionate prevalence of disability upon older adults still working) when a state’s allotment for youth PETS does not reach 15% and there is a need to serve such individuals who are at risk of losing their jobs due to the onset of a disability. This could be established in Section 361.37(b) where priority selection is given to individuals at risk of losing employment.

Additionally, an important issue regarding the definition of “student with a disability” is the timing of when the definition applies.  (See our recommendation above about the definition.)  The Iris Network recommends that §361.48(a)(1) be modified to state that the individual must meet the definition of “student with a disability” at the onset of any pre-employment transition service.  This would allow for a continuation of services that is not interrupted by a switch to another funding source (e.g., regular VR funds).

The preamble to the NPRM states that certain activities, such as a VR counselor’s involvement in IEP meetings, can be met through alternative means – such as video-conferencing and telecommunication.  The Iris Network recommends that §361.48(a)(4)  be modified to include these alternative options for participation in meetings on a student’s IEP.

§361.53

Section 101(a)(8) of WIOA made a significant change to comparable services and benefit requirements.  Accommodations and auxiliary aids and services are now subject to a search for comparable services and benefits from other sources before a DSU can provide the service.  RSA is proposing changes to §361.53 to implement this both at the counselor level and at the state policy level through changes to requirements for interagency agreements for the coordination of services.  Prior to the WIOA Amendment, accommodations and auxiliary aids and services were considered to be support services and rarely provided as a stand-alone service.  That is why such services were previously exempt from a search for comparable services and benefits. 

COMMENT:

Although the law has changed, the proposed regulations should be revised to state clearly that accommodations and auxiliary aids and services must be exempt from a comparable benefit search if such support services are needed by an individual to access the other exempt services identified in the Act and in proposed §361.53(b), which are unchanged from the previous regulations.  It is critical that the final regulations make clear that the provision of accommodations and auxiliary aids and services are exempt from a search for comparable services and benefit when needed by an individual to access or participate in the exempt VR services listed in §361.53(b).  RSA cannot require that a restriction be placed on a support service that is needed to access an exempt service required by an individual.

§361.65(a)(3)

Proposed §361.65(a)(3) implements the required set-aside of 15% of VR funding for the provision of pre-employment services to students with disabilities.  The proposed regulation implements section 101(d) of the Rehabilitation Act and clearly states that the reservation of funds applies to the state as a whole – and not to each DSU separately.  This is particularly important because DSUs that serve only blind and visually impaired individuals are likely to have a difficult time meeting the 15% set-aside due to the demographics of the population they serve. 

COMMENT:

It is critical that this provision continues to be interpreted to permit the 15% set-aside to apply to the state and not separately to each DSU in a state.  Furthermore, The Iris Network also urges that RSA must clarify that the 15% set-aside does not include state matching funds.  If matching funds were included, it would be even more difficult to meet the set-aside amount for many state agencies.

Section 363.22

This section sets aside 50% of allotted supported employment services for youth and students with disabilities.

COMMENT:

The same concern exists here as with the 15% set-aside because individuals with blindness face a scarcity of resources due to the extremely high percentage of onset later in life.  Similar exemptions should be made in situations where the allotted 50% is not depleted for a state, and funds could otherwise go toward assisting individuals who require such services in order to retain employment after developing a disability later in life.

§363.23(b)

In proposed §363.23(b), RSA has made a policy decision that in-kind contributions will not be allowable for matching purposes with regard to the 50% set-aside for supported employment services to youth with the most significant disabilities. 

COMMENT:

The Iris Network takes issue with this policy position.  RSA argues that the State Supported Employment Program is supplemental to the State VR Services Program, which does not allow in-kind contribution as match.  However, The Iris Network points out that language in the WIOA statute makes a case for a broader interpretation regarding match under the SE Program. 

Specifically, Sec. 606(b)(7)(I) of the Rehabilitation Act as amended by WIOA states, in part, that the 10% matching funds can come “directly or indirectly from public or private entities.”  This language supports that in-kind contributions are allowable for matching purposes under the State Supported Employment Program. 

If this is not corrected, DSUs will struggle to find matching funds for a program that did not require match in the past.  The Iris Network recommends that §363. 23(b) be deleted when the Part 363 regulations are finalized.

RSA also contends in the preamble to the NPRM that not allowing in-kind match would make it easier for DSUs to document match for the State Supported Employment Program.  This is not an accurate assumption given that DSUs are used to accounting for in-kind contributions as allowable match under both the Independent Living Program for Older Individuals who are Blind and the Independent Living State grant program that is now administered by the U.S. Department of Health and Human Services.

Section 363.53(b)(ii)

This section requires that an individual receiving supported employment services may receive additional short-term services for up to six months. Short term services will then be terminated if an individual is not placed into a competitive integrated setting. Even if an individual is in a competitive setting, but it is not integrated, short-term services will be stopped.

COMMENT:

Six months is not a sufficient amount of time to secure all the necessary services that an individual who is blind may require, especially if that individual has additional disabilities. As a result, it is recommended to strike “six months” and replace it with “not to exceed 18 months.” This will allow for flexibility and additional time to assist in overcoming obstacles and enhancing the odds for job retention.

In conclusion, The Iris Network appreciates the opportunity to review these proposed regulations and offer the foregoing comments for improvement.  If any clarification of our comments would be helpful, please do not hesitate to contact me.  I can be reached via email at jphipps@theiris.org, or by phone at 207.518-5005.

Respectfully submitted,

 

James E. Phipps, MBA/JD
President & Executive Director

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