Disability Coordinator Orientation

OBJECTIVES Review of Major Program Requirements 6.14 R1-R9 2

Objectives 1.Provide an overview of PRH Disability Program requirements. 2.Review relevant resources and tools available to assist disability coordinators (DCs) in meeting disability-related requirements. 3

PRH 6.14 Disability Requirement PRH 6: 6.14 R1 (a-b) R1 – Disability Coordinators PRH 6: 6.14 R2 (a-c); PRH 1: 1.4 R1-4; Exhibit 5-1 and Appendix 107 R2 - Applicant File Review (AFR) PRH 6: 6.14 R3 (a-c); PRH 2: 2.2, R1 (b11); PRH 2.2, R1 (d4) and PRH 2: 2.2, R2 (g) R3 – Reasonable Accommodation PRH 6: 6.14, R4 (a-c); PRH 2: 2.2, R1 (b11); PRH 2.2, R1 (d4) and PRH 2: 2.2, R2 R4 – Introduction to Center Life 4

PRH 6.14 Disability Requirement (cont.) PRH 6: 6.14 R5 (a-f) R5 – CIS Disability Data Collection and Accommodation Plans PRH 6: 6.14 R6 (a-c); R6 – Partnerships and Resources PRH 6: 6.14 R7(a-b); R7 – Referral Process PRH 6: 6.14, R8 (a-e); Exhibit 5-2 R8 – Readily Achievable Barrier Removal PRH 6: 6.14, R9 Exhibit 5-4 R9 – Staff Training 5

Job Corps Disability Website – Disability Coordinator Orientation Section 6

DISABILITY COORDINATORS (DCs) PRH Requirements 6.14 R1 7

DC Requirement a)Appoint DCs to oversee the program. The health and wellness manager (or a health staff designee) and academic manager (or an academic staff designee) will function as DCs to oversee the program. May choose to a hire full or part time DC rather than appoint DCs in academic and health. b)The roles and responsibilities of each of the DCs will be defined in an Standard Operating Procedure (SOP) R1 8

Other Responsibilities of the DC  As a DC, your responsibilities include: Ensuring that all required Disability Program components are implemented, monitored, and maintained in an effective manner. Demonstrating commitment and soliciting buy-in to disability initiative (leadership). Delegating responsibilities. Encouraging all staff to take ownership of the program R1 9

DC Responsibilities SOP 10

APPLICANT FILE REVIEW PRH Requirements 6.14 R2 11

Applicant File Review (AFR) Requirements a)Applicant file review process should be defined in SOP. b)Applicant files must be processed in 30 days. c)All center procedures must include: A file tracking method – Location where files are sent and logged through final disposition. Responsibilities and roles of team members. Process for reviewing files to include denial process. Process for reasonable accommodation R2 a-c 12

AFR Requirements (cont.) c)All center procedures must include: (cont.) A process for withdrawals. The timeframe to complete the process. Storage, transmission and maintenance of the file (Appendix 607). * Note these requirements are also outlined in (PRH 1:1.4 R1-4 and Appendix 107) 6.14 R2 a-c 13

AFR Resources  Webinars: Center Responsibilities in the Applicant File Review Process o Explains the center’s role in applicant file review from the time the file arrives on center until there is a final disposition on the file –Process perspective Center Responsibilities in the Applicant File Review Process – Completing the Health Care Needs/Direct Threat Assessments o Explains the clinical staff’s review of the applicant file, the purpose of the direct threat and health care needs assessments, and the completion of the actual assessment paperwork. –Clinical review perspective 14

REASONABLE ACCOMMODATION PRH Requirements 6.14 R3 15

Reasonable Accommodation (RA) Requirements a)A reasonable accommodation process is defined in an SOP (PRH 5: Exhibit 5-1) so that applicants/students may request and receive reasonable accommodations (RA). Applicant/students who request accommodations and/or provide documentation must be engaged in an interactive process to consider/determine accommodation needs R3 a-c What does engaging in the interactive process mean? 16

The RA Process  Requesting  Determination of need  Ensuring appropriate documentation  Reviewing a request  Determining reasonableness  Entering the accommodation plan  Notifying Staff  Determining accommodation effectiveness 6.14 R3 a-c 17

The RA Process (cont.)  Documenting the process  Maintaining the accommodation file  Storing accommodation and disability documentation 6.14 R3 a-c 18

RA Requirements (cont.) b)The DCs will coordinate the center’s reasonable accommodation process. c)During Career Transition Readiness all students will receive information about workers rights and responsibilities including reasonable accommodation in the workplace (3.21, R2 (g)) R3 Appdx. 605 a-c 19

RA Resources  Policy (PRH): Appendix 605 Job Corps Reasonable Accommodation Guidelines  Policy Support: The RAC Guide (JC Disability website)  Webinar: Reasonable Accommodation Process RAC Guide  Job Corps Disability website: Reasonable Accommodation section 20

Tools for Staff: Career Transition Counselors 21

Tools for Staff: Career Transition Counselors 22

INTRODUCTION TO CENTER LIFE PRH Requirements 6.14 R4 23

Introduction to Center Life a)Provide new students with information leading to an understanding of opportunities and benefit available with the Disability Program (PRH 2: 2.2, R1 (b11)).. b)Provide a variety of opportunities to meet and interact with the DCs (PRH 2.2, R1 (d4)). c)The student handbook should include information about the Disability Program (PRH 2: Section 2.2, R2) R4 a-c 24

Introduction to Center Life Resources  Brochure: Reasonable Accommodation Brochure available on the Job Corps Disability website can be customized for your center  Webinar: Disability Sensitivity Inclusive Environments 25

Introduction to Center Life Resources  Job Corps Disability Website: DC pictures with name and titles Sample student handbook language that can be customized for your center 26

CIS DISABILITY DATA AND ACCOMMODATION PLANS PRH Requirements 6.14 R5 27

CIS Disability Data and Accommodation Plans a)A DC accurately enters the required data in the disability data collection and accommodation plan icons in CIS after student arrives R5 a-f Job Corps is required to collect data on the number and types of participants with disabilities served by the program. 28

 The legal definition of who is a person with a disability.  Then we need to know and understand Job Corps policies related to these legal requirements. So what are a couple of main points we really have to understand to be able to meet this requirement? 29

The Legal Foundation and Policy Basis  The ADA, now known as the Americans with Disabilities Act Amendments Act (ADAAA), was reauthorized in Updated EEOC Guidelines were released in  Certain changes to this law affect how we determine who is considered a person with a disability. The requirements that directly affect Job Corps are outlined in the Background section of PRH 6: Appendix R5 Appdx. 605 a-f 30

Defining Disability…  A disability is a physical or mental impairment that substantially limits one or more major life activities…  Key terms: Physical/Mental impairment Substantially limits Major Life Activities 31

Major Life Activities  Major life activities has been expanded to include major bodily functions such as the immune system, normal cell growth, digestive, bowel, bladder, neurological, brain, respiratory, circulatory, endocrine, and reproductive functions. Certain impairments will virtually always be found to result in substantial limitation in performing certain life activities. Examples from the ADAAA regulations include deafness, blindness, intellectual disability, etc. 32

Mitigating measures  Mitigating measures are things such as medications, medical equipment or supplies, hearing and mobility support devices, prosthetics, etc.  Other than ordinary eyeglasses/contact lenses, the beneficial effects of mitigating measures shall not be considered in determining whether a person is someone with a disability or not. For example, experiencing periods of stability due to the use of a medication does not preclude a person from being determined to be a person with a disability. 33

Temporary Conditions  The effects of an impairment lasting less than six months can be substantially limiting if sufficiently severe. Typically, impairments that last only a short period of time are not covered  For example, the individual may have a severe injury such as a broken back, etc. This must be determined on an individualized basis. 34

Episodic or remission  An impairment that is episodic or in remission meets the definition of disability if it would be substantially limiting when it is active. Examples of impairments that may be episodic include epilepsy, hypertension, asthma, diabetes, major depressive disorder, bipolar disorder, and schizophrenia. Again, as with mitigating measures, for example, experiencing periods of stability due to the use of a medication does not preclude a person from being determined to be a person with a disability. 35

Substantially limits  An impairment does not need to prevent or severely or significantly restrict a major life activity to be considered “substantially limiting.” Nonetheless, not every impairment will constitute a disability and determination of whether an impairment substantially limits a major life activity still requires an individualized assessment.  The ADAAA states that the definition of disability should be interpreted in favor of broad coverage of individuals. 36

Impairments that are Virtually always Substantially Limiting  Deafness substantially limits hearing.  Blindness substantially limits seeing.  An intellectual disability substantially limits brain function.  Partially or completely missing limbs or mobility impairments requiring the use of a wheelchair substantially limit musculoskeletal function.  Autism substantially limits brain function. 37

Impairments that are Virtually always Substantially Limiting (cont.)  Cancer substantially limits normal cell growth.  Cerebral palsy substantially limits brain function.  Diabetes substantially limits endocrine function.  Epilepsy substantially limits neurological function.  Human Immunodeficiency Virus (HIV) infection substantially limits immune function.  Multiple sclerosis substantially limits neurological function. 38

Questions to consider in determining when to count students as having a disability  Does the student have a physical or mental impairment?  What major life activity(ies) are impacted?  Does the impairment substantially limit the student from performing the major life activity(ies) as compared to most people in the general population?  If the impairment is episodic or in remission; would it be substantially limiting when it is active? 39

Questions to consider in determining when to count students as having a disability  Is the student is taking medication or using some other mitigating measure? What would his/her condition be like without the benefit of medication or other supports? What were the symptoms and the student’s condition prior to the benefit of medication or other supports? Is the use of a mitigating measure causing any limitations?  How long are the effects of an impairment expected to last? If fewer than 6 months, how severe is the impairment? 40

Let’s Summarize!  Do not spend a lot of time analyzing whether a student meets the definition of disability; the disability assessment should be done quickly and not demand extensive analysis.  The disability data collection process is not an exact science. Use your best judgment, be consistent, and be prepared to explain your rationale. 41

Conclusions  Under the reauthorized ADAAA, more individuals will be substantially limited. Remember, the ADAAA reminds us to interpret the definition of disability in favor of broad coverage; when in doubt enter the disability and move on. Focus on the interactive process to determine the need for accommodation. 42

Testing Accommodations Disability Data Entry Requirement b)TABE testing accommodations must be entered prior to the administration of the first TABE test. If the applicant/student has either requested accommodations or provided documentation of the disability, then the applicant must be engaged in the RA process prior to arrival if an applicant and prior to the TABE test if disclosed upon arrival R5 Appdx. 605 a-f 43

Data Access Requirements c)Only the DCs will have access to the CIS disability data entry screens. d)A health and wellness or an academic designee can be appointed and given access to enter accommodation plans R5 Appdx. 605 a-f 44

Center Staff Access to Accommodation Plans e)All center staff providing accommodations will have access to the accommodation plan report in CIS. *Talk with center POC to ensure appropriate access has been provided to staff R5 Appdx. 605 a-f 45

Plan Content Restrictions f)Accommodation plans will not contain any medical or diagnostic information. This may include: o Disclosure of disability o Reference to types of documentation (IEP, Evaluations) o Prescription information o Psychological or Medical evaluations/test results o Health-related case management notes o References to treating provider or facility (AA meetings, therapy appts.) All health-related information is to be maintained in the student health record. X 6.14 R5 Appdx. 605 a-f 46

Disability Data and Accommodation Plan Resources  Job Corps Community website: CIS Wellness and Accommodation Module Technical Guide o Switched from CIS to CIS 3G as of 5/20/13  Webinar: CIS Wellness and Accommodation Module (by JCDC)  Wellness Accommodation Access Graphic 47

PARTNERSHIPS AND RESOURCES PRH Requirements 6.14 R6 48

Partnerships and Resources Requirements a)Develop resources and partnerships with outside agencies and programs. Focus on assistance with identifying or providing accommodations support that promotes students independence and employability R6 a-c 49

Staff Involvement b)The Business Community Liaison staff and other appropriate staff should be involved in the process R6 a-c 50

Partnership Tool c)Document efforts by completing the: Disability Partnership Tool on the Job Corps Community website or o Center’s Customized Partnership Tool available from your Regional Disability Coordinator R6 a-c 51

Ways to Build Partnerships  Develop a reciprocity relationship with your local vocational rehabilitation agency.  Network (e.g., provide information about Job Corps or invite to center) with local disability organizations (e.g., centers for independent living, one stops, school systems, colleges/universities).  Educate local employers about hiring people with disabilities.  Have prospective partners take a tour of center and invite them to serve on Community Relations or Industrial Relations Councils. 52

Partnership Resources  Webinars: Developing Partnerships BookShare State Assistive Technology Programs Job Accommodation Network (JAN) 53

REFERRAL PROCESS PRH Requirements 6.14 R7 54

Referral Process Requirement a)A written referral/feedback system documenting: When a student discloses and may want accommodations, or When staff suspects a student may have a disability impacting his or her success in Job Corps R7 a-b 55

Referral Form Storage Requirement b)All referral forms will be stored in the student’s accommodation file or in the student’s health record if no accommodation exists R7 a-b 56

READILY ACHIEVABLE BARRIER REMOVAL PRH Requirements 6.14 R8 57

Readily Achievable Barrier Removal Requirement  Centers must consider readily achievable barrier removal – can include easily accomplished and inexpensive measures that would make the center more accessible to those with disabilities (Exhibit 5-2) R8 Exh. 5-2 a-e

Architectural/Physical Accessibility a)Determine potential improvements to the physical accessibility of the center of the center (e.g. ramps, elevators, adjustable work stations, restrooms, etc.) R8 Exh. 5-2 a-e

Programmatic Accessibility  Determine potential improvements to the programmatic accessibility of the center (e.g. communication options, large print, disability related displays) R8 Exh. 5-2 a-e

Accessibility Plan c)Develop an accessibility plan with priorities and next steps based on the results of the ADA Checklist for Readily Achievable Barrier Removal and Center Accessibility Tool. Ex. Recreation staff will work with the BCL to invite Paralympic organizations to build awareness and assist students with disabilities in recreational activities. Ex. The food service line is not accessible, therefore student volunteers will assist student as needed. Ex. The RAC will be trained on how to use the relay system to support students who are deaf or hard of hearing R8 Exh. 5-2 a-e

Accessibility Plan (cont.)  The accessibility plan Is NOT intended to be used to determine compliance for new construction or facility alteration. Is separate from the center’s facility survey requirement in PRH 5: R8 Exh. 5-2 a-e

Other Accessibility Plan Considerations d)The accessibility plan is to be reviewed and updated annually by June 30th (Exhibit 5-2). e)The safety and facilities maintenance staff should play a primary role in completing the plan with support from managers in all areas R8 Exh. 5-2 a-e

Readily Achievable Barrier Removal Resources  Webinars: Readily Achievable Barrier Removal 64

STAFF TRAINING PRH Requirements 6.14 R9 65

Staff Training Requirements  Centers will provide disability-related staff training in accordance with PRH Chapter 5, Exhibit 5-4. Yearly training for all center staff about the Disability Program or a Disability-related topic Reasonable accommodation training for new staff within the 1st 90 days of employment and yearly thereafter. o To meet this requirement, staff must complete the Supporting Students with Disabilities in the Job Corps Program training available in the Staff Instructional Management Online Network (SIMON), located in CITRIX. o Certificates of completion should be maintained by Human Resource staff R9 Exh. 5-4

Staff Training Resources  Job Corps Disability website: Training materials section for packaged trainings and ideas  Disability Partners: Community resources to provide training  SIMON: New Staff Disability Program Orientation to train new hires (SIMON is now in Citrix) 67

SIMON 68

RESOURCES PRH Requirements

Monthly Disability Coordinator Teleconference/ Webinar  Each month a primary topic that is current and relevant to centers is selected and presented along with a resource of the month. Routine attendance likely will assist you in achieving a better ROCA score and running a better overall Disability Program. 70

Job Corp Community Webinars – Event Registration  Disability Program and Support-related webinars are scheduled on a regular basis. You may sign up to attend these webinars via the Event Registration link located on the left hand side of the webpage on the Job Corps Community Website. After registration, you will receive an with connection instructions that will contain some information similar to this: Course URL: The Course URL should be accessed from outside the Job Corps Citrix environment. Groups participating via a speaker phone and a PC should designate a moderator in the group to voice questions from the group or to collect the group’s questions to ask at a later time. This will help minimize confusion and avoid having too many people trying to talk at the same time. 71

Appendix 606  Legal obligation to communicate with individuals with disabilities (WIA). 72

Appendix 607  Describes requirements for transmission, storage, and confidentiality of medical, health, and disability- related information. 73

Job Corps Disability Website 74

Supporting Students with LD 75

Job Accommodation Network (JAN) 76

Regional Disability Coordinators  Boston, and Philadelphia Regions – Kristen Philbrook  Atlanta Region – Jasmin Merritt  Dallas Region – Laura Kuhn  Chicago and San Francisco Regions – Kim Knodel 77

Test Your Knowledge!  Where can I find sample disability-related student handbook language? JC Disability Website  How often should all staff training be conducted? Annually  The roles and responsibilities of DCs’ should be defined in an _______. In an SOP 78

Test Your Knowledge!  If staff suspect students have a disability they should complete a _______ form and forward it to the DC. Referral  True or False: You are in this by yourself. False! Of course not! 79

QUESTIONS ANY 80