Oklahoma department of rehabilitation services Dale Rogers Training Center Workforce Innovation and Opportunity Act. Steps for Transition and Subminimum Wage Presenters: Kimberly Osmani, M.Ed. Theresa Flannery

What’s New For Youth? The passing of WIOA has introduced limitations on the use of subminimum wage Employment First focus What is expected from the DRS, and state and local educational agencies?

What’s New For Youth? Continued Increased focus on competitive integrated employment Statewide agreements between DRS and OSDE Required activities before a youth can be considered for subminimum wage Vocational Rehabilitation Services Pre-Employment Transition Services Career counseling and information and referral services Local and state educational agencies cannot contract with entities for the purpose of youth working at subminimum wage.

Youth Documentation Key components Documentation of transition services under IDEA provided by the schools Documentation of Pre-Employment Transition Services by DRS, community rehabilitation provider (CRP), or other contractor Application to DRS Eligibility/non-eligibility Case closure (not successful)

Youth Documentation IEPs may include what is necessary for completion of transition services. Other documents may include time sheets from work experiences, progress reports, transition assessment results, etc. Documentation from WAT programs would be included. Provider documentation of Pre-ETS (developed by DRS)

STEPS for Those Seeking Subminimum Wage Employment

Documentation of Transition Services and/or Pre-Employment Transition Services The youth/family must request any documentation of transition services completed under IDEA through the school. The documentation must be submitted to DRS by the school. While still in high school, the team must identify what transition services may not have been covered that are still in need. DRS must provide (or contract to have provided) the Pre-ETS identified as needed by/for the youth.

Pre-Employment Transition Services Counseling on career opportunities (DRS, CRP, Contractor) Work readiness including social skills and independent living skills (school, provider) Work experiences (paid and unpaid, internships, volunteering) Counseling on postsecondary opportunities (DRS, CRP, Contractor) Self-advocacy skills, including peer mentoring (DRS, CRP, contractors, etc.)

VR Eligibility The youth MUST apply for services through DRS. www.okdrs.gov Scroll down to Application for Services Fill out application AND health checklist. Have parent/guardian or adult youth (??) sign and submit by mail, fax, or scan/email to local DRS office. Best practice is to submit documentation of disability at this time. Keep a copy for your records, along with the date submitted. Office locator http://www.okdrs.org/office_locator

VR Eligibility If determined ineligible, DRS will gather documentation and provide a cover letter indicating what is included as well as date of ineligibility, and will provide all of that to the youth. The youth will then take all of that to the subminimum wage employer of choice. Subminimum wage employers cannot admit youth under 25 without ALL required documentation.

VR Eligibility If determined eligible, DRS will work with the youth to develop their plan for employment and provide services to help them achieve their vocational goal. If, with appropriate supports and accommodations, it is determined that the youth will not achieve a successful employment outcome, the case will be closed with an indication that CIE was not an outcome. DRS will then gather documentation and provide a cover letter indicating what is included as well as date of case closure/ineligibility, and will provide all of that to the youth. The youth will then take all of that to the subminimum wage employer of choice.

VR Eligibility If determined eligible, DRS will work with the youth to develop their plan for employment and provide services to help them achieve their vocational goal. If, with appropriate supports and accommodations, it is determined that the youth IS ABLE to achieve a successful employment outcome, DRS will continue to provide the necessary services until the vocational goal is achieved and employment outcome has occurred. The case will then be closed successfully.

What Ifs… The youth received all required transitional services and has ample documentation from the school? The team still needs to see what (if any) Pre-ETS DRS might need to provide. The youth did not receive all required transition services and does not have documentation from the school? DRS must provide Pre-ETS identified as necessary (unless school still has time to provide). The youth does not want to apply for DRS services or does not want Pre-ETS services? They will not be able to seek subminimum wage employment until they turn 25 years old.

What Ifs… The youth communicates that he or she does NOT want to work toward CIE? DRS may determine the youth ineligible and provide documentation they could then take to an employer of subminimum wage. However, some provider agencies may not take this documentation because of regulations. The youth was already employed at subminimum wage prior to 7/22/2016? None of this applies, and they just need to receive annual counseling and information referral.

What Ifs… The youth was already employed at subminimum wage prior to 7/22/16 and decides to switch to a different subminimum wage employer? If still age 24 or under, they must go through all of the steps mentioned previously. If age 25 or older, this does not apply.

Other Topics DRS Provider and School documentation forms Ideas for Pre-ETS Services to groups Summer programs Order of selection kosmani@okdrs.gov or 405-343-8071 tflannery@drtc.org or 405-946-4489