1. 1 Click to edit Master title style Disability Coordinator Orientation Kimberly Jones, Regional Disability Coordinator

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

3. 3 Disability Program Requirements Disability Program is now its own section in PRH, Chapter 6 – Section 6.14 Why? To change perception of disability as only a health and wellness program and ensure a center wide focus To clarify and ensure consistency among existing requirements; additional requirements have not been created Recent Changes

4. 4 PRH 6.14 Disability Requirements RequirementCitation Disability CoordinatorsPRH 6: 6.14, R1 (a-b) Applicant File Review Process PRH 6: 6.14, R2 (a-c); PRH 1: 1.4 R1-4; Exhibit 5-1 and Appendix 107 Reasonable Accommodation PRH 6: 6.14, R3 (a-c) and Appendix 605; Exhibit 5-1 and PRH 3: 3.21, R2 (g) Introduction to Center Life PRH 6: 6.14, R4 (a-c); PRH 2: 2.2, R1 (b11); PRH 2.2, R1 (d4) and PRH 2: 2.2, R2 CIS Disability Data Collection and Accommodation Plans PRH 6: 6.14, R5 (a-f) Partnerships and ResourcesPRH 6: 6.14, R6 (a-c) Referral ProcessPRH 6: 6.14, R7 (a-b) Readily Achievable Barrier RemovalPRH 6: 6.14, R8 (a-e), and Exhibit 5-2 Staff TrainingPRH 6: 6.14, R9; Exhibit 5-4

5. 5 Resource: Job Corps Disability website – Disability Coordinator Orientation section PRH 6.14 Disability Requirements

6. 6 Click to edit Master title style PRH 6.14, R1 Disability Coordinators

7. 7 Requirements: PRH 6: Section 6.14, R1 (a-b) 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) PRH 6.14, R1 Disability Coordinators

8. 8 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 PRH 6.14, R1 Disability Coordinators

9. 9 Resource: Job Corps Disability website – Disability Coordinator SOP PRH 6.14 Disability Requirements

10. 10 Click to edit Master title style PRH 6.14, R2 Applicant File Review

11. 11 Requirements: PRH 6: Section 6.14, R2 (a-c) a)Applicant file review process should be defined in SOP b)Applicant files must be processed in 30 days PRH 6.14, R2 Applicant File Review

12. 12 Requirements: PRH 6: Section 6.14, R2 (a-c) 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 Process for withdrawals 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) PRH 6.14, R2 Applicant File Review

13. 13 Resources: Webinar – Center Responsibilities in the Applicant File Review Process (Administrative Process) Webinar – Center Responsibilities in the Applicant File Review Process (Health Care Needs/Direct Threat) PRH 6.14, R2 Applicant File Review

14. 14 Click to edit Master title style PRH 6.14, R3 Reasonable Accommodation

15. 15 Requirements: PRH 6: Section 6.14, R3 (a-c) and Appendix 605 a)Defined in an SOP (PRH 5: Exhibit 5-1) a process: −for applicants/students to request and receive reasonable accommodations (RA) and −to ensure applicant/students who request accommodations and/or provide documentation engage in the interactive process to consider/determine functional limitations PRH 6.14, R3 Reasonable Accommodation

16. 16 PRH 6.14, R3 Reasonable Accommodation Request Documentation Reviewing a request Evaluating a request Denying a request Developing an accommodation plan Notification Determining accommodation effectiveness Recordkeeping Request Determination of need Ensuring appropriate documentation Reviewing a request Determining reasonableness Entering the accommodation plan Notification/Viewing the plan Documenting the process Maintain the accommodation file Storing accommodation and disability documentation Process Then Process Now

17. 17 Requirements: PRH 6: Section 6.14, R3 (a-c) and Appendix 605 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)) PRH 6.14, R3 Reasonable Accommodation

18. 18 Resources: PRH – Appendix 605 Job Corps Reasonable Accommodation Guidelines Webinar – Reasonable Accommodation Process Job Corps Disability website – Reasonable accommodation section Job Corps Disability website – The RAC Guide PRH 6.14, R3 Reasonable Accommodation

19. 19 Resources: Job Corps Disability website – Tools for Staff: Career Transition Counselors PRH 6.14, R3 Reasonable Accommodation

20. 20 Click to edit Master title style PRH 6.14, R4 Introduction to Center Life

21. 21 Requirements: PRH 6 Section 6.14, R4 (a-c) 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)) PRH 6.14, R4 Introduction to Center Life

22. 22 Requirements: PRH 6: Section 6.14, R4 (a-c) c)The student handbook will include information about the Disability Program (PRH 2: Section 2.2, R2) PRH 6.14, R4 Introduction to Center Life

23. 23 Resources: Brochure – Reasonable Accommodation Brochure available on the Job Corps Disability website can be customized for your center Webinar – Disability Sensitivity Inclusive Environments PRH 6.14, R4 Introduction to Center Life

24. 24 Resources: Job Corps Disability website – DC pictures with name and titles Job Corps Disability website – Sample student handbook language that can be customized for your center PRH 6.14, R4 Introduction to Center Life

25. 25 Click to edit Master title style PRH 6.14, R5 CIS Disability Data and Accommodation Plans

26. 26 Requirements: PRH 6: Section 6.14, R5 (a-f) a)A DC accurately enters the required data in the disability data collection and accommodation plan icons in CIS after student arrives Job Corps is required to collect data on the number and types of participants with disabilities served by the program PRH 6.14, R5 CIS Disability Data and Accommodation Plans

27. 27 The ADA, now known as the Americans with Disabilities Act Amendments Act (ADAAA), was reauthorized in 2009, 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 Appendix 605. PRH 6.14, R5 CIS Disability Data and Accommodation Plans

28. 28 What is the definition of a disability? A disability is a physical or mental impairment that substantially limits one or more major life activities… PRH 6.14, R5 CIS Disability Data and Accommodation Plans

29. 29 What is a physical impairment? A physical impairment is any physiological disorder or condition, cosmetic disfigurement, or anatomical loss affecting one or more of the following body systems: PRH 6.14, R5 CIS Disability Data and Accommodation Plans NeurologicalRespiratory (Including speech organs) Special sense organsReproductive CardiovascularGenitourinary DigestiveSkin Hemic and LymphaticImmune EndocrineCirculatory Musculoskeletal

30. 30 What is a mental impairment? A mental impairment is any mental or psychological disorder, such as intellectual disability, organic brain syndrome, emotional or mental illness, and specific learning disabilities. PRH 6.14, R5 CIS Disability Data and Accommodation Plans

31. 31 What are major life activities? PRH 6.14, R5 CIS Disability Data and Accommodation Plans

32. 32 What is are major life activities? Other major life activities include the operation of a major bodily function, including functions of the immune system; special sense organs and skin; normal cell growth ; and digestive, genitourinary, bowel, bladder, neurological, brain, respiratory, circulatory, cardiovascular, endocrine, hemic, lymphatic, musculoskeletal, and reproductive functions. The operation of a major bodily function includes the operation of an individual organ within a body system. PRH 6.14, R5 CIS Disability Data and Accommodation Plans

33. 33 Substantial Limitation Determination When making a determination on whether an individual is substantially limited in performing a major life activity: The term “substantially limits” should be construed broadly in favor of expansive coverage; “substantially limits” is not meant to be a demanding standard and the determination should not require extensive analysis. The determination requires an individualized assessment. PRH 6.14, R5 CIS Disability Data and Accommodation Plans

34. 34 Substantial Limitation Determination An impairment need not prevent, or severely or significantly limit a major life activity in order to be considered substantially limiting. Nonetheless, every impairment does not constitute a disability. An impairment is a disability if it substantially limits the ability of an individual to perform a major life activity as compared to most people in the general population. PRH 6.14, R5 CIS Disability Data and Accommodation Plans

35. 35 Substantial Limitation Determination: Mitigating Measures When determining whether a person is substantially limited in a major life activity, the beneficial effects of mitigating measures, except ordinary eyeglasses or contact lens, will be ignored. Mitigating measures are things such as medications, medical equipment or supplies, hearing and mobility support devices, prosthetics, assistive technology, therapy, etc. PRH 6.14, R5 CIS Disability Data and Accommodation Plans

36. 36 Substantial Limitation Determination and Mitigating Measures This means that someone who is stable on medication can still be considered an individual with a disability. If the use of mitigating measure causes any limitations, they will be considered The use of a mitigating measure cannot be required PRH 6.14, R5 CIS Disability Data and Accommodation Plans

37. 37 Substantial Limitation Determination: 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 PRH 6.14, R5 CIS Disability Data and Accommodation Plans

38. 38 Substantial Limitation Determination: 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. PRH 6.14, R5 CIS Disability Data and Accommodation Plans

39. 39 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 Cancer substantially limits normal cell growth PRH 6.14, R5 CIS Disability Data and Accommodation Plans

40. 40 Impairments That Are Virtually Always Substantially Limiting 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 PRH 6.14, R5 CIS Disability Data and Accommodation Plans

41. 41 Get past the definition of disability ‒ 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. PRH 6.14, R5 CIS Disability Data and Accommodation Plans

42. 42 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? PRH 6.14, R5 CIS Disability Data and Accommodation Plans

43. 43 Questions to consider in determining with to count students as having a disability Is the impairment one that is considered virtually always substantially limiting? If 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? PRH 6.14, R5 CIS Disability Data and Accommodation Plans

44. 44 How long are the effects of an impairment expected to last? If fewer than 6 months, how severe is the impairment? PRH 6.14, R5 CIS Disability Data and Accommodation Plans

45. 45 A lot 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, the focus should be on the interactive process to determine the need for accommodation. PRH 6.14, R5 CIS Disability Data and Accommodation Plans

46. 46 Requirements: PRH 6: Section 6.14, R5 (a-f) b)TABE testing accommodations entered prior to the administration of the first TABE test PRH 6.14, R5 CIS Disability Data and Accommodation Plans

47. 47 Requirements: PRH 6: Section 6.14, R5 (a-f) c)Only the DCs will have access to the CIS disability data entry screens d)Generally only DCs will have access to the entry screen; however designee can be appointed and given access to enter accommodation plans PRH 6.14, R5 CIS Disability Data and Accommodation Plans

48. 48 Requirements: PRH 6: Section 6.14, R5 (a-f) e)All center staff providing accommodations will have access to the accommodation plan report in CIS PRH 6.14, R5 CIS Disability Data and Accommodation Plans * Talk with center POC to ensure appropriate access has been provided to staff

49. 49 Requirements: PRH 6: Section 6.14, R5 (a-f) f)Accommodation plans will not contain any medical or diagnostic information −This may include: Disclosure of disability Reference to types of documentation (IEP, Evaluations) Prescription information Psychological or Medical evaluations/test results Health-related case management notes References to treating provider or facility (AA meetings, Therapy appts) –Should be maintained in student health record PRH 6.14, R5 CIS Disability Data and Accommodation Plans X

50. 50 Resources: PRH 6: Section 6.14, R5 (a-f) Job Corps Community website – CIS Wellness and Accommodation Module Technical Guide –Switched from CIS to CIS 3G as of 5/20/13 Wellness Accommodation Access Graphic Webinar – Provided by JCDC PRH 6.14, R5 CIS Disability Data and Accommodation Plans

51. 51 Click to edit Master title style PRH 6.14, R6 Partnerships and Resources

52. 52 Requirements: PRH 6: Section 6.14, R6 (a-c) 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 PRH 6.14, R6 Partnerships and Resources

53. 53 Requirements: PRH 6: Section 6.14, R6 (a-c) b)The Business Community Liaison staff and other appropriate staff should be involved in the process PRH 6.14, R6 Partnerships and Resources

54. 54 Requirements: PRH 6: Section 6.14, R6 (a-c) c)Document efforts by completing the: −Disability Partnership Tool on the Job Corps Community website or −Center’s Customized Partnership Tool available from your Regional Disability Coordinator PRH 6.14, R6 Partnerships and Resources

55. 55 Ways to build partnerships: Develop a relationship with your local vocational rehabilitation agency Learn about the services the Job Accommodation Network (JAN) provides to Job Corps centers 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 PRH 6.14, R6 Partnerships and Resources

56. 56 Resources: Webinar – Developing Partnerships Webinar – Bookshare PRH 6.14, R6 Partnerships and Resources

57. 57 Resources: Webinar – State Assistive Technology Programs Webinar – Job Accommodation Network (JAN) PRH 6.14, R6 Partnerships and Resources

58. 58 Click to edit Master title style PRH 6.14, R7 Referral Process

59. 59 Requirements: PRH 6: Section 6.14, R7 (a-b) 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 PRH 6.14, R7 Referral Process

60. 60 Requirements: PRH 6: Section 6.14, R7 (a-b) b)All forms will be stored in the student’s accommodation file or in the student health record if no accommodation exists PRH 6.14, R7 Referral Process

61. 61 Click to edit Master title style PRH 6.14, R8 Readily Achievable Barrier Removal

62. 62 Requirements: PRH 6: Section 6.14, R8 (a-e) Centers must consider readily achievable barrier removal – easily accomplished and inexpensive measures that staff members can do to make the center more accessible to those with disabilities (Exhibit 5-2) PRH 6.14, R8 Readily Achievable Barrier Removal

63. 63 Requirements: PRH 6: Section 6.14, R8 (a-e) To accomplish this task centers must: a)Determine potential improvements to the physical accessibility of the center of the center (e.g. ramps, elevators, adjustable work stations, restrooms, etc.) PRH 6.14, R8 Readily Achievable Barrier Removal

64. 64 Requirements: PRH 6: Section 6.14, R8 (a-e) To accomplish this task centers must: b)Determine potential improvements to the programmatic accessibility of the center (e.g. communication options, large print, disability related displays) PRH 6.14, R8 Readily Achievable Barrier Removal

65. 65 Requirements: PRH 6: Section 6.14, R8 (a-e) 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 − This 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: 5.10 PRH 6.14, R8 Readily Achievable Barrier Removal

66. 66 Requirements: PRH 6: Section 6.14, R8 (a-e) d)To be reviewed and updated annually by June 30 th (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. PRH 6.14, R8 Readily Achievable Barrier Removal

67. 67 Resources: Webinar – Readily Achievable Barrier Removal PRH 6.14, R8 Readily Achievable Barrier Removal

68. 68 Click to edit Master title style PRH 6.14, R9 Staff Training

69. 69 Requirements: PRH 6: Section 6.14, R9 Centers will provide disability-related staff training in accordance with PRH Chapter 5, Exhibit 5-4 PRH 6.14, R9 Staff Training

70. 70 Requirements: PRH 6: Section 6.14, R9 Annual disability training for all center staff and Training for new staff within the 1st 90 days of employment PRH 6.14, R9 Staff Training

71. 71 Resources: PRH 6: Section 6.14, R9 Job Corps Disability website – Training materials section for packaged trainings and ideas Partners – Community resources to provide training SIMON – New Staff Disability Program Orientation to train new hires (SIMON is now in Citrix) PRH 6.14, R9 Staff Training

72. 72 Click to edit Master title style Resources

73. 73 Legal obligation to communicate with individuals with disabilities (WIA) Resources Appendix 606

74. 74 Describes requirements for transmission, storage, and confidentiality of medical, health, and disability-related information Resources Appendix 607

75. 75 Resources Job Corps Community Website – Disability

76. 76 Resources Supporting Students with LD

77. 77 Resources Job Accommodation Network (JAN)

78. 78 Boston Region, Atlanta and Philadelphia Regions – Kristen Philbrook kristen.philbrook@humanitas.com Dallas Regions – Laura Kuhn laura.kuhn@humanitas.com Chicago and San Francisco Regions – Kim Jones kim.jones@humanitas.com Resources Regional Disability Coordinators

79. 79 Test Your Knowledge 1. Where can I find sample disability-related student handbook language? 2. How often should all staff training be conducted? 3. The roles and responsibilities of DCs’ should be defined in an _______. 4. If staff suspect students have a disability they should complete a _______ form and forward it to the DC. 5. In the PRH, I can find information regarding the process for an applicant/student with a disability to request reasonable accommodations to participate in the Job Corps program in Appendix ____.

80. 80 Questions

81. 81 THANK YOU!