1. Transition Services: Collaborating With VR
Sheila Ward, Senior Consultant

2. Objectives
To identify the available Pre-Employment Transition Services Pre-ETS
To understanding the two pathways students may access Pre-ETS
To understand VR’s initiative to expand provider capacity
To understand Section 511 of WIOA
To identify the three requirements for students who wish to go into employment after high school

3. Giving state and local education agencies the ability to collaborate to help students with disabilities achieve their transition goals
This collaboration leads to increased graduation rates, lower drop-out rates, and increased post-school outcomes (indicators 1, 2, and 14)

4. Pre-ETS
Career Exploration Services help students with disabilities, ages 14-21
Learn soft skills and appropriate behaviors through hands-on work experiences
Leading to:
Career pathways
Skills for the 21st Century workforce
Pre-Employment Transition Services are defined as Career Exploration services that provide opportunities for students with disabilities to explore themselves, their options, and learn what is necessary as they transition out of school into the world of work. Pre-ETS offer training in soft skills, social skills, employability skills, and self-advocacy skills as well as an opportunity for students to learn what behaviors are appropriate in the workplace. Students have an opportunity to practice the skills they learned while developing relationships and building confidence and self-esteem. All of these services lead to students making an informed decision about their career pathways and possessing skills required for the 21st Century workforce.

5. WIOA: Pre-ETS Postsecondary Educational Counseling* Work-Based
Develop, practice, and apply skills
Get an idea of what work is about
Identify needed work accommodations
Build relationships leading to job references
Gain self-confidence
Postsecondary Educational Counseling*
Work-Based
Learning Experiences
Work Readiness Training
Job Exploration Counseling
Through the STAR Program, VR will deliver specific (limited) Pre-Employment Transition Services. These include:
Job Exploration Counseling – which includes skills, abilities, aptitudes, interest assessments, and postsecondary options
Work Readiness Training – which is a 20 hour course that focuses on employability and work-readiness skills
Self-Advocacy Training and Peer Mentoring – teaches you how to speak up for yourself and make decisions about your own life to become more independent
Postsecondary Educational Counseling* – provides an awareness of career pathway options with job and career information
Work-Based Learning Experiences – which include hands-on training for employability skills
Please note that Postsecondary Educational Counseling and Peer Mentoring are currently being added but are not yet available state-wide. More information and training will be provided prior to rolling out these services.
Self-Advocacy Training and Peer Mentoring*

6. Pathways to Pre-ETS Referral Pre-ETS only
STAR Portal Referral
Referral
Students have two options to receive Pre-Employment Services (Pre-ETS). The first is a referral made through the Student Transition Activities Record (STAR) Portal. This type of referral is a mechanism for VR to provide limited Pre-ETS to students who are considered potentially eligible. This means they have not applied to or been found eligible for VR services in the past. They have a documented disability so are presumed to be eligible for these specific services.
The second choice, “traditional” VR, you may be more familiar with. For students who choose to go through the full VR program, they must apply and be found eligible. As with Pre-ETS referrals made through the STAR portal, students who go through the traditional VR process can also receive Pre-ETS, however they also may be eligible to receive additional services and supports to assist them in attaining their post-school outcomes.
Pre-ETS only
No application or eligibility required
Pre-ETS at Application
Additional services at IPE

7. Pre-ETS Referrals made through the STAR Portal
For Potentially Eligible Students
More independent, self-directed, require fewer services or supports to be successful
With disability documentation
Current IEP, 504, other
Access to specific* Pre-ETS are available
Referrals come:
Public, charter, DJJ or
Self-referral (private or postsecondary education/training programs
*Peer Mentoring is not available to STAR Participants
To participate in STAR, participants must meet the following requirements:
They must be at least 14 years of age but not more than 21 years of age
Enrolled in secondary or postsecondary education or training program (trade schools, colleges, universities, etc.) – Even though secondary is indicated, we are required to look at the age, not grade of the student.
Have a current IEP, 504 Plan, or other documentation identifying student is being served by school as a student with a disability*
and not be a current VR applicant or customer
Star referrals are submitted through an online portal by individuals identified at public, charter, and DJJ residential facilities. Students/families may self-refer when in private schools or postsecondary education or training programs.
Peer mentoring will only be available to VR customers as this is a service for student who require additional supports

8. VR Application and eligibility required
Access to Pre-ETS and additional services based on employment goal which may include:
Supported employment
Time-limited treatment
Job placement assistance
Assistive technology and devices
Transportation
Postsecondary education or training
If students require additional or more intensive support services such as
Supported employment
Time-limited treatment
Job placement
Assistive technology and devices and/or
Transportation
they should be encouraged to apply to VR where these additional services may be available if they qualify for services.
If a student with a disability has an employment goal that will likely require postsecondary education or training, VR may be able to assist. In this case, the student will need to apply to VR as this is not available through STAR.

9. Choosing the Best Pathway
Discuss with VR staff, student, family
Look at disability documentation, specifically services, accommodations and modifications being accessed by the student
Ask questions such as how much support is provided at home or in class on assignments, tests, homework to ensure success

10. Transition Youth Programs
2018 Summer Youth Program
Work-Based Learning Experience (WBLE)
Project SEARCH
High School High Tech
Inclusive Postsecondary Education Programs

11. Transition Resources
VR Transition Youth Page

12. Transition Resources
Pre-ETS Page
Office Directory

14. Becoming a Pre-ETS Provider
Pre-ETS Application
Special consideration for School Districts
Provider trainings for interested school districts will be held this summer

15. WIOA: Section 511
Limitations on the Use of Subminimum Wage for YOUTH 24 and under
I wanted to share information on Section 511 of the Workforce Innovation and Opportunity Act and the resulting amendments to the Rehab. Act. W.I.O.A has promoted significant change within VR. VR can now deliver services earlier and a richer option of services for youth beginning at age 14.
The intent of this particular section of the law was to place the focus on employment as an option for all individuals regardless of their disability which compliments Florida’s focus on Employment First as outlined in Florida Statue and to provide additional opportunities for youth and adults. Today I will focus on the information pertaining to youth..
Section 511 ensures that youth have the opportunity to receive comprehensive services including information, services and experiences, to assist them to become employed in a competitive integrated employment setting. These additional services and supports are designed to increase the employment rate for individuals with disabilities. We know that there is an exceptionally high unemployment and underemployment rate for individuals with disabilities in Florida and in the nation.
Just a review of terminology -Subminimum Wage employment is only available through a 14(c)employer– Section 14 © of the DOL Wage and Hour authorizes employers,, to pay special wages - wages less than the Federal minimum wage - to workers who have disabilities. In Florida it is usually offered in Sheltered Employment Programs and Day Programs provided by many providers. There are approximately 50 of these employers across the state. You can look on the DOL website to see where these programs are in your area.
It is important to note that the required documentation we are going to discuss is important for these 14 (C) employers. They can not legally hire a youth 24 and younger without documentation from VR. If they hire a youth in subminimum wage and do not have the appropriate documentation from VR the DOL can require the employer to pay back wages based on minimum wage, can fine the employer, or in exceptional cases remove their 14 (C) certificate.
DOL Wage and Hour is the enforcement agency and will be doing reviews for compliance.

16. Section 511 of WIOA- Limitations on Subminimum Wage for YOUTH
As of 7/22/16 Youth with disabilities 24 and younger are not eligible for Subminimum Wage Employment unless the youth has completed the following three requirements:

17. Section 511 of WIOA- Limitations on Subminimum Wage for YOUTH
Transition services under IDEA and/or Pre-ETS under W.I.O.A
Youth applied to VR and was:
found ineligible or
found eligible
Received Career Counseling Information and Referral Services from VR Counselor
So what are the requirements. There are three required elements. There may only be three but it ends up being rather complex. The three requirements are
1. Pre-ETS/Transition services Youth apply to VR Youth receive Career Counseling
As you can see these requirements require a close collaboration between the education system and VR.
It is critical that youth and their families are made aware of this change in the law. They need to understand that their next step in their employment journey or adult life begins with VR. Youth and families need to understand that if they elect not to apply for VR services that it will restrict their option in seeking subminimum wage employment until after they turn 25 and only then if they agreed to receive career counseling Information and Referral Services.
It is very important that everyone who works with youth understands that Individuals may not go directly from school to a 14 C employer for subminimum wage employment.
The law is clear that all youth 24 and under must apply for VR services prior to becoming eligible for subminimum wage- no exceptions are allowed under the law at this time.
W.I.O.A assigns VR the responsibility for documenting compliance with the requirements but also requires that schools provide documentation regarding Pre-ETS/Transsition Services.
It also makes it more important then ever that our partnership is effective in referring students to VR as early as possible so that they have the opportunity to receive the mandated transition or pre-ets services before graduating.
#1: The importance of the documentation of completion of appropriate pre-ets/transition services is one of the requirements that a youth must meet if he/she wishes to work in subminimum wage employment. The youth must have documentation of either preemployment or transition services to enter into subminimum wage. Without this documentation the youth cannot work in subminimum wage employment until age 25.
Schools are required to provide this documentation and we have an additional slide with what information VR and the youth would need.
#2 the youth must apply for VR services, if they refuse to apply, they would not be eligible to work in subminimum wage until they are 25 and have fulfilled the other requirements.
a. So youth apply for VR. What is next? VR must determine eligibility and most students would be determined eligible. VR has worked hard to introduce additional services to help students who might have more significant needs to be successful. There are however some youth who may not benefit from VR services but this is determined only after clear and convincing evidence obtained from Trial Work Experiences of a sufficient variety over a sufficient period of time that the disability is so significant that the individual is unable to benefit from VR in terms of an employment outcome.. This should be the exception not the usual.
The majority of youth will be determined eligible and offered a wide variety of services. Hopefully, they will be successful in achieving competitive integrated employment. However, if they are unable to achieve the employment outcome, despite working toward the employment outcome with reasonable accommodations and support for a reasonable period of time they could choose to close their case and move on to subminimum wage employment opportunities as long as they met the other two requirements of Transition/Pre-ETS Services and Career Counseling.
New Guidance ) New Guidance: another option has been shared: after applying a youth can make an informed choice not to pursue CIE, the youth can be determined ineligible and may enter subminimum wage employment as long as they meet the other two criteria.
3. Counselors will provide Career Counseling to all VR customers.
Excellent Resource:
US Department of Labor, Wage and Hour
Fact Sheet #39H: The WIOA and Limitations on Payment of Subminimum Wage under Section 14 (c) of the Fair Labor Standards Act

18. Additional Guidance
Workface Innovation Technical Assistance Center (WINTAC) has shared the following recent guidance.
There are exceptions where youth can be determined ineligible for VR services any time after application and may receive the required documentation to allow participation in subminimum wage employment, if they make an informed choice not to pursue competitive integrated employment.
They still must meet the three basic requirements.
Applied for VR Services
Documentation of participation in Transition Services through IDEA or Pre-Employment Transition Services through VR
Received Career Counseling from a VR Counselor

19. Required LEA Documentation
Information regarding receipt and completion of Pre-Employment or Transition Services should include:
Name of Youth
Description of Service or Activity Completed, including name of provider, date services completed, and signature of personnel documenting the completion
Signature of person transmitting the documents
Date and method of delivery (e.g., hand-delivered, faxed, ed, etc.) by which document was transmitted to the youth or VR Counselor

20. VR’s Primary Responsibility
Determine eligibility for VR services
Provide quality Career Counseling and Information Services
Develop an Individual Plan for Employment (IPE) that contains a variety of services designed to assist youth in obtaining a successful employment outcome
VR has been focusing on adding services such as Discovery, Customized Employment, a variety of work experience options, Self-Advocacy, Peer Mentoring, etc. in an effort to provide more intensive services for those individuals with most significant disabilities who in the past may not have felt VR was an option.
It is so important that youth “grow” up so to speak understanding these options and their choices for the future.

21. Additional VR Responsibility
WIOA assigned VR the responsibility to provide documentation to 14 (C) Employers for eligible youth, when appropriate to do so
Employers and families sometimes call this documentation a “14 (C) letter”
Documentation can only be provided if all three required elements are met
Documentation may be formatted as a letter or a checklist
We would like to hope that there would be limited requests for this letter/form. VR wants to be able to serve the youth who apply for services.

22. The Mystery of the Sought After 14 (C) Letter
A letter from VR documenting that a youth has met all of the required elements. This letter is required before a youth can be hired to participate in subminimum wage employment.
Individuals or Families may call and request a 14 (c) letter
What they are asking for is a letter with the documentation that they need to be eligible to participate in subminimum wage
There are no letters available without applying to VR and completing the three key requirements

23. Obtaining a 14 (c) Letter from VR
To obtain a letter from VR, youth must have:
Appropriate documentation of Transition Services under IDEA and/or Pre-Employment Transition services under WIOA
Applied to VR and be determined Eligible (AND IF ELIBIBLE RECEIVE SERVICES) or Ineligible (FOLLOWING VR POLICY)
Received Career Counseling by a VR counselor
The letter documents the above information with services and dates completed.

24. This is a sample of a format that might be used to document compliance with all three requirements or it may be provided in a letter format. The law only specifics the minimum requirements but not the format.

25. Additional Information of Interest
The law does not apply to youth 24 and younger who:
Are not pursuing subminimum wage employment
May work in sheltered workshops or for a 14 (C) employer if they are going to be paid minimum wage or higher
May participate in adult day training programs that offer nonwage, meaningful day training activities
With anything new there are often questions that arise. It is important to note that this section of W.I.O.A only pertains to individuals 24 and younger who wish to pursue subminimum wage. There are youth who because of the complexity of their disabilities who may be best served by a nonwork oriented day program. The law does not preclude that option for individuals.
In summary:
Youth may not go straight from school to participate in subminimum wage employment
They must have documentation of having participated in Pre-ETS or Transition Services either through schools or VR
They must apply for VR services - if they are not eligible and meet the other two requirements they can pursue subminimum wage employment
If they are eligible but after having an IPE developed are not successful or decide they do not wish to pursue competitive integrated employment their case can be closed and they can pursue subminimum wage employment as long as they have met the other two requirements
They must have received career counseling

26. VR Employment Programs Contacts
Carmen Dupoint
Pre-ETS, DJJ, Summer Youth Program, High School High Tech, Inclusive Postsecondary Education, Vendor Liaison
Kirk Hall
Supervisor
Jan Pearce
Supported and Customized Employment, Discovery, WIOA 511, Pre-ETS
Regina Rice
Project SEARCH, Self-Employment, Pre-ETS, Career Source, CAPE, Apprenticeships, Individual Placement and Support, Peer Specialist Program
Sheila Ward
Pre-ETS, Student Transition Activities Record (STAR), Self-Advocacy Training, Work-Based Learning Experiences for School Districts, VR/SD Liaison
General Transition Questions: