Employment First Procedure

CARROLL COUNTY BOARD OF DEVELOPMENTAL DISABILITIES

PROCEDURE: EMPLOYMENT FIRST:

These procedures were developed to be compliant with the Employment First Policy.  The Board will ensure that every work age adult and children in transition services will be given the opportunity of the path to employment. County Board Employment Specialist and/or SSA staff will be responsible to identify the path to employment for any Carroll County resident age 14 or older who is eligible for Board services or has an Individual Education Plan in a Carroll County School District.

Background Information and Definitions

Vocational Rehabilitation

Vocational Rehabilitation (VR) provides direct, personalized services to help individuals with disabilities obtain or retain jobs.  Person-centered planning techniques are utilized to develop an Individualized Plan for Employment (IPE) that will lead to gainful, community employment. 

Vocational Rehabilitation Application Process
Once an individual has expressed that competitive, integrated employment is their desired outcome; an application for services can be submitted by the individual interested in services or by family, friends, county board staff, education or mental health professionals, etc.  Application information including the applicant’s name, address, age, nature of disability, Social Security number, sex, and referral source will be needed at time of application.

Vocational Rehabilitation Referral Guidance
County boards are encouraged to provide documentation of the disability (FED form, OEDI, COEDI, Medicaid Level of Care, Social Security benefits letter, related medical and psychological reports, etc.) and information about the individual’s functional limitations to expedite this process. During this time, SSAs can document that the employment service is not otherwise available to the person and Medicaid-funded (HCBS waiver) employment services (discovery or vocational assessment, for example) could be provided.

Vocational Rehabilitation Eligibility

Upon receipt of the application, VR staff will schedule an interview with the individual and others the individual has chosen to accompany them.  In the interview, VR staff will gather information needed in order to determine eligibility. 

Eligibility for Vocational Rehabilitation services is based on four criteria:

  1. Individual has a physical, cognitive and/or mental impairment;
  2. The impairment results in a substantial impediment to employment;
  3. The individual can benefit from VR services in terms of an employment outcome; and
  4. The individual requires VR services to prepare for, secure, retain, or regain employment consistent with the individual’s unique strengths, resources, priorities, concerns, abilities, capabilities, interests and informed choice

Competitive Integrated Employment Definition

Means work that is performed on a full-time or part-time basis (including self-employment):

  • For which an individual:
    • is compensated at a rate that is at or above minimum wage but not less than the customary rate paid by the employer for the same or similar work performed by other employees who are not individuals with disabilities, and who are similarly situated in similar occupations by the same employer and who have similar training, and skills;
    • In the case of an individual who is self-employed, yields an income that is comparable to the income received by other individuals who are not individuals with disabilities, and who are self-employed in similar occupations or on similar tasks and who have similar training, experiences and skills;
    • is eligible for the level of benefits provided to other employees;
  • That is at a location where the employee interacts with other persons who are not individuals with disabilities (not including supervisory personnel or individuals who are providing services to such employee) to the same extent that individuals who are individuals with disabilities and who are in comparable positions interact with other persons, and;
  • That is appropriate, presents opportunities for advancement that are similar to those for other employees who are not individuals with disabilities who have similar positions.

Path to Community Employment

This guidance follows the four places on the Path to Community Employment as outlined in the Employment First Rule (5123:2-2-05), which considers an individual’s unique strengths, interests, abilities, preferences, resources and desired outcomes as they relate to Community Employment. The four places on the Path to Community Employment are:

  • Place One: The individual is already engaged in community employment and needs support for job stabilization, job improvement, or career advancement;
  • Place Two: The individual expresses a desire to obtain community employment but is not currently employed and needs support to obtain employment or identify career options and employment opportunities;
  • Place Three: The individual is unsure about community employment and needs support to identify career options and employment opportunities and the economic impact for the individual of the decision to work; or
  • Place Four: The individual does not express a desire to work and needs support to learn more about careers and employment opportunities and the economic impact for the individual of the decision not to work.

HCBS-funded supported employment

According to the DODD Supported Employment-Community Rule (5123: 2-9-15, D:3), the service and support administrator shall ensure that documentation is maintained to demonstrate that the service provided as supported employment-community to an individual enrolled in a waiver is not otherwise available as vocational rehabilitation services funded under section 110 of the Rehabilitation Act of 1973, 29 U.S.C. 730, or as special education or related services as those terms are defined in section 602 of the Individuals with Disabilities Education Improvement Act of 2004, 20 U.S.C. 1401.

  • It is important to note that the county board is not required to obtain an ineligibility form from OOD before HCBS waiver-funded employment services can be provided. Documentation (e.g. case note) that the service is not otherwise available through VR should be maintained in the individual’s ISP.
  • It should also be noted that this language does not require an individual to first be referred to OOD before HCBS waiver-funded employment services can be provided. See below for further guidance. 
Place One:    I have a job but would like a better one or to move up
Refer to VR?Maybe
As mentioned above, an individual must require vocational rehabilitation services to obtain or maintain employment. If an individual already has a job that is competitive and integrated, they might be eligible for OOD services.  For example, if the person has a substantial impediment to employment and requires VR services to be able to work more hours than they are currently working, or to keep their job.   For these types of situations, it would be helpful to contact your assigned VR liaison (if applicable) or local VR office to discuss whether or not a person should be referred based on his or her individual circumstances.  Staff at the local office can help direct you to the right person.   


Place Two:    I want a job! I need help to find one.
Refer to VR?Yes
If an individual desires competitive integrated employment and requires employment services in order to achieve that outcome, they can begin the application process at any time. The county board can assist the job seeker to apply for OOD services, where VR staff will schedule an intake interview, determine eligibility, provide any necessary assessments, develop a person-centered, Individualized Plan for Employment (IPE), authorize services, etc. to help that person achieve community employment. The liaison assigned to your area (if applicable) or staff at the local OOD office can assist you in determining which caseload (i.e. EF Partnership, OTSP, Bridges, Contracts, RCD, BSVI, etc.) can best serve the individual based upon program or contract criteria,  capacity and nature of the referral. The process for determining eligibility for OOD services should not take more than 60 days (OOD strives to make this determination within 30 days) depending on the availability of ready and existing documentation as mentioned above. In the event that an individual’s VR case has been recently closed without an employment outcome, Medicaid-funded (HCBS waiver) employment services can be accessed and the SSA can document that the individual’s case with VR has been recently closed.  However, it is important to note that VR services can be explored again as requested by the individual at any time in the future.
Place Three:    I’m not sure about work. I need help to learn more. Place Four:      I don’t think I want to work, but I may not know enough about it
Refer to VR?Maybe
An individual may be unsure about competitive integrated employment as a goal and may need discovery or other prevocational services in order to help inform their decision. Because the individual may not have made the decision of whether competitive integrated employment is their desired outcome, Medicaid-funded (HCBS waiver) employment services can be utilized to help the person make that choice. If the individual makes an informed decision that competitive integrated employment is their desired outcome, and they need employment services to achieve that goal, an application for OOD services can be completed at any time.  VR staff can also be available to talk with individuals and their families about VR services either individually or as a group to help inform their decision about whether a referral to VR is a possible next step. 
  1. The Carroll County Board will develop its strategic plan that will have an outline and periodically update its strategy and benchmarks for increasing the number of individuals of working age engaged in community employment services. The current goal is to place 4 individuals per year in community jobs.
  2. The Carroll County Board shall collaborate with workforce development agencies, vocational rehabilitation agencies, and mental health agencies in Carroll County to support individuals to obtain community employment.  Employment Supervisor will work with Carroll County Department of Job and Family Services, ADAMHS Board, Community Mental Health, OOD, and other local providers to support those eligible for Board services. This intent is for the Employment Supervisor to seek as much funding as possible through grants or reimbursement from agencies such as OOD. However, the Board is strongly committed to successful outcomes. Therefore, if the intake process and associated wait on establishing a case and approval for service inhibits a job placement then the Employment Supervisor will notify the Superintendent.  The Superintendent has the authority to approve using local funds to pay for job coaching and other community employment service costs.
  3. The Carroll County Board shall collaborate with school districts in the county to ensure

a framework exists for individuals approaching completion of a program or

service under Chapter 3323. of the Revised Code such that the county board

and school districts in the county use similar methods to support students

with developmental disabilities to obtain community employment. Through

this collaboration, the county board shall identify and attempt to resolve any duplication of efforts. The Employment Supervisor will work with each school district in Carroll County to help anyone on an IEP age 14 or older with their path to community employment. The Board shall provide transition to work services for Carroll Hills School students and local school district students on IEP’s age 14 and up.

  • The Carroll County Board shall disseminate information to individuals served, families,

schools, community partners, employers, and providers of services about

resources and opportunities, including Medicaid buy-in and other work incentive programs, that facilitate community employment.

  • The Carroll County Board’s Employment Supervisor shall collect and submit to the department individual-specific data regarding the cost of non-Medicaid employment services, employment outcomes for individuals who receive non-Medicaid employment services, and employment outcomes for individuals who do not receive paid

employment services but who are engaged in competitive employment or

community employment.

  • Carroll County Board’s Employment Supervisor shall submit to each individual’s team at least once every twelve months, or more frequently as decided upon by the team, a

written progress report that demonstrates that services provided are consistent

with the individual’s identified community employment outcome and that the

individual receiving services has obtained community employment or is

advancing on the path to community employment. The progress report for

each individual participating in prevocational services shall describe progress

on achievement of desired outcomes as set forth in the individual plan or

individual service plan, as applicable.

5123:2-2-05 4

  • Carroll County Board’s Employment Supervisor shall collect and submit to the department individual-specific data regarding employment services and employment

outcomes including but not limited to, type of services provided, how

individuals obtained employment, hours worked, wages earned, and

occupations. The data shall be submitted through a web-based data collection

system developed and maintained by the department.

  • Carroll County Board’s Employment Supervisor shall disseminate aggregate data regarding employment services and employment outcomes including but not limited to,

type of services provided, how individuals obtained employment, hours

worked, wages earned, and occupations, to individuals seeking employment

services and others upon request. The data shall be disseminated in a manner

that does not disclose confidential information regarding individuals

receiving employment services.

  1. The Carroll County Board Employment Supervisor and/or SSA will assist each individual of working age and each individual approaching completion of a program or service under Chapter 3323 of the Revised Code shall participate in an individualized person-centered planning process in accordance with, as applicable, rule 5123:2-1-11 of Administrative Code or 42 C.F.R. 483.440 as in effect on the effective date of this rule, to identify the individual’s unique strengths, interests, abilities, preferences, resources, and desired outcomes as they relate to community employment.  The person-centered planning process shall begin with a review of available information to determine what additional information is needed and what supplemental situational and/or other formal or informal evaluations are needed to discover this information.  For individuals who receive public assistance, the importance of obtaining benefits analysis shall be emphasized to enable the individual to make informed decisions regarding employment.  Resources available for obtaining benefits analysis shall be       identified for the individual prior to job development.
  • The person-centered planning process shall include identification and documentation of:

(a) The individual’s place on the path to community employment, that is:

            (i) The individual is already engaged in community employment                                                     and needs support for job stabilization, job improvement, or                                          career advancement;

            (ii) The individual expresses a desire to obtain community                                                               employment but is not currently employed and needs                                                   support to obtain employment or identify career options                                                      and employment opportunities;

            (iii) The individual is unsure about community employment and                                                     needs support to identify career options and employment                                                        opportunities and the economic impact for the individual of                                                 the decision to work; or

            (iv) The individual does not express a desire to work and needs                                                       support to learn more about careers options and                                                                 employment opportunities and the economic impact for the                                                 individual of the decision not to work.

      (2) The individual’s desired community employment outcome.

(a) Clearly defined activities, services, and supports necessary for the                                             individual to achieve or maintain community employment, job                                      improvement, or career advancement.

(3) The results of the person-centered planning process, including the individual’s                         desired outcomes as they relate to community employment, shall be                              integrated into the individual plan or individual service plan, as applicable.

(4) The results of the person-centered planning process shall be reviewed at least                           once every twelve months and whenever a significant change in                                                employment, training, continuing education, services, or supports occur or                         is proposed.

  • The Employment Supervisor is responsible to ensure those of working age who request employment services receive Job Exploration Training (JET). Each year those interested in JET will submit resumes for consideration. Employment Supervisor and other County Board staff will interview applicants. The Board will fund the JET program to ensure individuals have an opportunity to explore community job options. The JET program shall be extended upon the approval of the Superintendent and local businesses as necessary throughout the year.
  • The Employment Supervisor will encourage and support job coach and transportation providers. The intent is for providers to perform as much job coaching and transportation as possible for those with Waiver funding and those without.  However, the Board intends to maintain a great relationship with community employers and will oversee and make adjustments as needed to ensure positive employment outcomes for those eligible for Board services.
  • The Board is committed to Community Employment for all working age adults eligible for Board services who want community employment. The Superintendent has the authority to commit Board resources of funding and staff for job coaching, transportation, JET, job development, community based assessments, job placement, and other employment development skills.

Effective Date: 4-1-2014

Mathual J. Campbell, Superintendent

Revised Date: 12-22-2015

Mathual J. Campbell, Superintendent

Revised Date: 8-2-2018

Mathual J. Campbell, Superintendent

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