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The Workforce Innovation and Opportunity Act (WIOA) requires VRS to have Pre-Employment Transition Services (Pre-ETS) available statewide to students with disabilities who are between ages 14 until 22. Our federal regulations state that we are required to “provide, or arrange for the provision of, [Pre-ETS] in collaboration with local education agencies” while also ensuring that we are not supplanting services customarily provided by schools under part B of the Individuals with Disabilities Education Act (IDEA).
Additionally, WIOA requires VRS to spend a minimum of 15% of our allocated federal funds on Pre-ETS. Since we began providing Pre-ETS in 2017, VRS staff have worked steadily and diligently to build our Pre-ETS programming in supporting success of students transitioning to work and meeting this spending mandate. As we wrap up federal fiscal year (FFY) 2024 at the end of this month, we are projected to have spent 27% of our federal funds on Pre-ETS. While I am so pleased that students are getting needed services that lead to their success in working and that we are meeting (and now exceeding!) our goal, unfortunately our budget does not allow us to continue on this spending trajectory. Adjustments need to be made to reduce our expenditures while still ensuring students get what they need.
Spending adjustments
Initially when VRS needed to spend 15%, we were able to be more flexible with how funds were spent. Now that we have met and exceeded the 15% baseline requirement, we must put more parameters around Pre-ETS spending.
The following are spending adjustments that VRS needs to make to help stay within budget:
- End funding toward work experiences that take place during school hours
VRS recognizes that school work-based learning (WBL) programs are a valuable way for students with disabilities to get support with obtaining and maintaining work experience. In fact, when VRS was not yet expending the full 15% requirement, we invested Pre-ETS funds to build the capacity of schools to offer this important programming. During years 2021-22, over $1.3 million was spent to have 240 special education teachers complete the training that allowed them to obtain the “Teacher Coordinator Work Based Learning” licensure endorsement from the Minnesota Professional Educator Licensing and Standards Board (PELSB).
At the same time, as noted above, VRS must avoid supplanting what schools provide during school hours.
Accordingly, when students have work experiences during school hours, schools need to provide appropriate staffing for students to find and keep those jobs while VRS will support students in work experiences outside of school hours (evenings, weekends, and summertime).
More specifically, VRS will need to discontinue authorizing for work experiences (short-term or intermediate), internships, on-the-job evaluations (OJEs), and work-based learning coaching during school hours.
These adjustments will take place over the course of the 2024-25 school year. That means if VRS has previously agreed to a work experience during the school day for a student, VRS will honor those. However, VRS will not offer any new work experiences that will take place during the school day.
In October there will be an E1MN survey that will go out to schools and VRS staff to understand how state agencies can help expand and enhance school work-based learning programs.
- Prioritize paid competitive integrated employment (CIE) work experience for students
E1MN leaders at DEED, MDE, and DHS have a collective vision: “All students with disabilities have paid competitive integrated employment work experience prior to earning their high school diploma.” Paid CIE work experience means a regular job in the community where an employer pays a prevailing wage (VRS also calls these “intermediate work experiences”).
To live into that vision, while aligning costs with our current budget parameters, we ask that VRS prioritize paid CIE work experiences and limit funding for experiences where VRS subsidizes the wages (i.e. short-term work experiences, internships, and OJE).
Furthermore, as a reminder, when a short-term work experience is deemed necessary as a step towards gaining paid CIE work experience, 120 hours is only a benchmark and not a required number of hours. VRS staff will consider the number of hours a student needs in order to gain the outcomes desired for the experience.
Partnerships with schools and our community partners are crucial.
Finally, I want to acknowledge that our partnerships with schools and our community partners have always been, and will continue to be, critical as we move forward together in making sure students with disabilities get all the support they need.
If you have questions, please reach out to the VRS staff person you’re working with and they can reach out for assistance from their managers, as needed. We'll work together to build a strong partnership that benefits the students we serve.
What is the DEED-Vocational Rehabilitation Services Community Partner and Stakeholder listserv?
The Vocational Rehabilitation Services (VRS) Division of the Minnesota Department of Employment and Economic Development (DEED) comprises the public Vocational Rehabilitation program, the Minnesota Extended Employment program, Independent Living services, Individual Placement and Supports grants, and Deaf and Hard-of-Hearing grants.
The DEED-VRS Community Partner and Stakeholder listserv is the communication platform for current VRS Community Partners, potential VRS Community Partners, and other interested stakeholders in Minnesota’s disability employment services system. We encourage you to subscribe if you are an interested stakeholder in Minnesota’s disability employment services system.
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