O S E R S Telework Forum May 21, 2007 Rob Groenendaal Program Specialist Rehabilitation Services Administration Office of Special Education and Rehabilitative Services U.S. Department of Education

1 Goals of the Telework Program Increasing access to technology for individuals with disabilities [through loans to purchase computers and other equipment, including adaptive equipment]; and Increasing access to technology for individuals with disabilities [through loans to purchase computers and other equipment, including adaptive equipment]; and Increasing employment opportunities and competitive employment outcomes for individuals with disabilities. Increasing employment opportunities and competitive employment outcomes for individuals with disabilities.

2 What Is Telework? What Is Telework? Telework includes work [as an employee or contractor or to become self-employed on a full-time or part-time basis] that can be effectively performed— from home; or from home; or from designated sites away from the office, such as work on the road or at a telework center. from designated sites away from the office, such as work on the road or at a telework center.

3 Purpose of Teleworking Teleworking should: “reduce or eliminate barriers to employment experienced by individuals with disabilities.”

4 Purpose of Technical Assistance Circular To give grantees the flexibility to design and implement the Telework program in a manner that will encourage applications for loans. To give grantees the flexibility to design and implement the Telework program in a manner that will encourage applications for loans. This is achieved by allowing grantees to design and implement their own policy and process to determine the appropriateness of loan requests on a case-by-case basis. This is achieved by allowing grantees to design and implement their own policy and process to determine the appropriateness of loan requests on a case-by-case basis.

5 Case-by-Case Determination A grantee’s policy and process to examine loan requests must be designed to establish that: 1. A person experiences a disability 2. A person’s disability creates a barrier or barriers to employment 3. A person’s proposed work overcomes that barrier or barriers

6 Case-by-Case Determination (cont’d.) 4. The proposed location is appropriate based on its relationship to the proposed work 5. The equipment to be purchased with the loan is necessary to make that form of telework possible at the proposed location

7 Establish Disability 1. A person experiences a disability How do you determine or establish that an individual has a disability?

8 Barriers to Employment 2. A person’s disability creates a barrier or barriers to employment. Common barriers include but are not limited to inadequate transportation, fatigue, inaccessible work environments, or the need for personal assistance. How do you determine an individual’s barrier or barriers to employment? Is there a link between the person’s disability and the barrier or barriers to employment created by that disability?

9 Proposed Work Overcomes Barriers Proposed Work Overcomes Barriers 3. The person’s proposed work overcomes a barrier or barriers to employment How can you determine if the type of work proposed overcomes the individual’s barrier or barriers to employment?

10 Appropriate Proposed Worksite 4. The proposed location is appropriate based on its relationship to the proposed work If the proposed type of work overcomes a barrier to employment, how do you determine if the worksite or environment is appropriate?

11 Equipment 5. The equipment to be purchased with the loan is necessary to make that form of telework possible at the proposed location If the worksite is appropriate, how do you determine what is needed to make the proposed work possible?

12 Equipment (cont’d.) 5. The equipment to be purchased with the loan meets the definition of equipment as established by your program Your program’s definition must be based on the definition in the Education Department General Administrative Regulations (EDGAR): “Equipment means tangible, nonexpendable, personal property having a useful life of more than one year and an acquisition cost of $5,000 or more per unit.... ” (34 CFR 80.3)

13 EDGAR Definition of Equipment (Part I) Tangible Tangible Nonexpendable Nonexpendable Personal property Personal property Useful life of more than one year Useful life of more than one year Acquisition cost Acquisition cost Grantee definition Grantee definition

14 Tangible Items able to be touched Items able to be touched Items having physical substance or material existence Items having physical substance or material existence Items having intrinsic monetary value Items having intrinsic monetary value

15 Nonexpendable Pertains to a supply item or piece of equipment that is not consumed, and does not lose its identity, in use, as a vehicle, machine, tool, piece of furniture, or instrument Pertains to a supply item or piece of equipment that is not consumed, and does not lose its identity, in use, as a vehicle, machine, tool, piece of furniture, or instrument Refers to supplies which are not consumed in use; and Refers to supplies which are not consumed in use; and Includes supplies which retain their original identity during period of use, such as machines, tools, and equipment. Includes supplies which retain their original identity during period of use, such as machines, tools, and equipment.

16 Personal Property Includes all property other than land and buildings attached to land Includes all property other than land and buildings attached to land Can be temporary or movable property (as distinguished from real estate) Can be temporary or movable property (as distinguished from real estate) Can include any asset other than real estate Can include any asset other than real estate May also be known as “movable property” and “movables” May also be known as “movable property” and “movables”

17 Useful Life of More than One Year Typical operating service life of an asset for the purpose it was acquired Typical operating service life of an asset for the purpose it was acquired The number of years that depreciable business equipment or property is expected to be in use The number of years that depreciable business equipment or property is expected to be in use

18 Acquisition Cost The price and all fees paid required to obtain a property The price and all fees paid required to obtain a property According to EDGAR: $5,000 or more per unit According to EDGAR: $5,000 or more per unit

19 EDGAR Definition of Equipment (Part II) “Equipment means tangible, nonexpendable, personal property having a useful life of more than one year and an acquisition cost of $5,000 or more per unit. A grantee may use its own definition of equipment provided that such definition would at least include all equipment defined above.” (34 CFR 80.3)

20 Grantee Definition of Equipment A grantee may use the flexibility provided by EDGAR to develop a definition that meets the needs of its telework program. The per unit acquisition cost can be less than $5,000. The per unit acquisition cost can be less than $5,000. The useful life can be less than one year. The useful life can be less than one year. If a program’s definition allows loans for training, inventory, supplies, etc., these MUST be attached to a specific piece of equipment to be used for a specific telework job. If a program’s definition allows loans for training, inventory, supplies, etc., these MUST be attached to a specific piece of equipment to be used for a specific telework job.

21 Policies and Procedures Grantees should develop policies and procedures based on the technical assistance circular (TAC) to guide their decision-making about loans. Grantees should develop policies and procedures based on the technical assistance circular (TAC) to guide their decision-making about loans. These policies and procedures must be submitted to RSA upon completion for review. These policies and procedures must be submitted to RSA upon completion for review.

22 Where to Go for More Information Rob Groenendaal, Program Specialist