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United States Government Accountability Office: 
GAO: 

Report to the Ranking Member, Committee on Education and the 
Workforce, House of Representatives: 

July 2012: 

Students With Disabilities: 

Better Federal Coordination Could Lessen Challenges in the Transition 
from High School: 

GAO-12-594: 

GAO Highlights: 

Highlights of GAO-12-594, a report to the Ranking Member, Committee on 
Education and the Workforce, House of Representatives. 

Why GAO Did This Study: 

The transition out of high school to postsecondary education or the 
workforce can be a challenging time, especially for students with 
disabilities. Multiple federal agencies fund programs to support these 
students during their transition. In 2003, GAO reported that limited 
coordination among these programs can hinder a successful transition. 
GAO was asked to provide information on the (1) challenges students 
with disabilities may face accessing federally funded transition 
services; and (2) extent to which federal agencies coordinate their 
transition activities. GAO reviewed relevant federal laws, 
regulations, and agency documents from Education, HHS, Labor, and SSA, 
which administer the key programs that provide transition services. 
GAO also administered a data collection instrument to gather program 
information from these agencies. Finally, GAO interviewed various 
stakeholders, including state and local officials, service providers, 
parents, and students with disabilities, in five states selected based 
on the number of federal grants they received to fund transition 
services. 

What GAO Found: 

Students with disabilities face several longstanding challenges 
accessing services that may assist them as they transition from high 
school into postsecondary education or the workforce—services such as 
tutoring, vocational training, and assistive technology. Eligible 
students with disabilities are entitled to transition planning 
services during high school, but after leaving high school, to receive 
services that facilitate their transition they must apply as adults 
and establish eligibility for programs administered by multiple 
federal agencies. Students with disabilities may face delays in 
service and end up on waitlists if these programs are full. In 
addition, while all five states GAO contacted have taken steps to 
coordinate their transition services and assist families with the 
transition process, officials said that it is still difficult for 
students and their parents to navigate and for providers to coordinate 
services across different programs. Officials and parents GAO spoke 
with also noted a lack of sufficient information or awareness of the 
full range of service options available after high school on the part 
of students with disabilities, parents, and service providers. In 
addition, state and local officials said students with disabilities 
may not be adequately prepared to successfully transition to life 
after high school. This may be due, in part, to limited opportunities 
to engage in vocational and life skills training or obtain work 
experience while in school. 

Figure: Students Move from Services Provided through Their High School 
to Services Delivered through Multiple Programs: 

[Refer to PDF for image: illustration] 

Student with disabilities: 

While in high school: 
Eligible student entitled to services until graduating or leaving high 
school. 

After high school: 
Student must apply and be found eligible for services from individual 
programs. 

Source: GAO analysis of agency documentation, including postings and 
publications. 

[End of figure] 

The Departments of Education (Education), Health and Human Services 
(HHS), and Labor (Labor), and the Social Security Administration (SSA) 
coordinate transition activities to some degree, but their 
coordination has limitations and they do not assess the effectiveness 
of their efforts. One coordinating body involves all four agencies and 
focuses on transition services. However, that group’s primary 
coordination activity is information sharing among staff-level 
representatives rather than developing common outcome goals and 
establishing compatible policies for operating across agencies. Agency 
officials told GAO that a lack of compatible outcome goals for 
transitioning students and differences in statutory eligibility 
criteria are among the barriers that hinder interagency coordination 
for this population. While agencies collaborate to some extent, their 
efforts represent a patchwork approach and there is no single, formal, 
government-wide strategy for coordinating transition services for 
students with disabilities. Moreover, it is unclear what impact 
coordination has on service provision because agencies do not assess 
the effectiveness of their coordination activities. 

What GAO Recommends: 

To improve the provision of transition services for students with 
disabilities, GAO recommends that Education, HHS, Labor, and SSA 
develop an interagency transition strategy that addresses (1) 
operating toward common outcome goals for transitioning youth; (2) 
increasing awareness of available transition services; and (3) 
assessing the effectiveness of their coordination efforts. All four 
agencies agreed with the recommendation. 

View [hyperlink, http://www.gao.gov/products/GAO-12-594]. For more 
information, contact Revae E. Moran at (202) 512-7215 or 
MoranR@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Students with Disabilities Face Several Longstanding Challenges 
Accessing Federal Transition Services: 

Federal Agency Coordination of Transition Activities Has Limitations: 

Conclusions: 

Recommendation for Executive Action: 

Agency Comment and Our Evaluation: 

Appendix I: Scope and Methodology: 

Appendix II: Federal Programs that Provide Transition Services to 
Youth with Disabilities: 

Appendix III: Other Federal Coordination Efforts that Address 
Individuals with Disabilities, Including Students: 

Appendix IV: Comments from the Department of Education: 

Appendix V: Comments from the Department of Health and Human Services: 

Appendix VI: Comments from the Department of Labor: 

Appendix VII: Comments from the Social Security Administration: 

Appendix VIII: GAO Contact and Staff Acknowledgments: 

Related GAO Products: 

Tables: 

Table 1: Organizations Contacted: 

Table 2: Education Programs Providing Transition Services to Youth 
with Disabilities (Ranked by Funding Level): 

Table 3: HHS Programs Providing Transition Services to Youth with 
Disabilities (Ranked by Funding Level): 

Table 4: Department of Justice Program Providing Transition Services 
to Youth with Disabilities: 

Table 5: Labor Program Providing Transition Services to Youth with 
Disabilities: 

Table 6: SSA Programs Providing Transition Services to Youth with 
Disabilities (Ranked by Funding Level): 

Figures: 

Figure 1: Key Federal Legislation Providing for Services to Transition-
Age Students with Disabilities: 

Figure 2: Students Move from Services Provided through Their High 
Schools to Services Delivered through Multiple Programs: 

Figure 3: Federal Coordination Efforts Specific to Transition Services: 

Figure 4: Federal Coordination Efforts That Focus on Individuals with 
Disabilities or Youth: 

[End of section] 

United States Government Accountability Office: Washington, DC 20548: 

July 12, 2012: 

The Honorable George Miller: 
Ranking Member: 
Committee on Education and the Workforce: House of Representatives: 

Dear Mr. Miller: 

The transition from high school to postsecondary education or the 
workforce can be a challenging time for all students, and particularly 
for those with disabilities who may need additional services such as 
tutoring, vocational training, assistive technology, and other 
supports to achieve their goals. This can be a daunting process, and 
research has documented that students with disabilities are less 
likely than their peers to successfully make the transition. For 
example, as of February 2012, the employment rate for young adults 
ages 20 to 24 with disabilities was less than half the rate of their 
peers without disabilities. When young adults with disabilities do not 
successfully transition out of high school, they may face a lifetime 
of continued reliance on public assistance, potentially leading to 
substantial costs to the government and society. Although the total 
amount of federal money spent to support students with disabilities in 
transitioning out of high school is not known, the federal investment 
in educating students with disabilities is substantial. In 2011, the 
Department of Education (Education) awarded about $11.5 billion in 
federal grants to states to help ensure that 6.6 million students with 
disabilities--approximately 2.2 million of whom were of transition-age 
[Footnote 1]--received a free appropriate public education, as 
required by the Individuals with Disabilities Education Act (IDEA), a 
key piece of legislation pertaining to transition. IDEA requires that 
beginning not later than the first individualized education program 
(IEP) to be in effect when the student turns 16, school officials must 
include in the IEP postsecondary goals and the transition services 
needed to assist the student in reaching those goals.[Footnote 2] 

Students remain eligible for transition planning and services, as well 
as other IDEA services, until they exit high school. Once students 
exit high school, they are no longer entitled to federal transition 
services under IDEA.[Footnote 3] Instead, they may apply and be found 
eligible for a number of other separately administered federal 
programs that are authorized to provide services that can assist youth 
with disabilities in their transition to postsecondary education, 
employment, and independent living. GAO has reported on the need for 
better coordination among federal disability programs, including those 
serving students with disabilities.[Footnote 4] This is one reason 
that, as of 2011, federal disability programs remained on GAO's high 
risk list.[Footnote 5] In light of questions about the accessibility 
and coordination of transition services for students with 
disabilities, you requested we provide information on: (1) challenges 
students with disabilities may face accessing transition services 
under existing federal programs; and (2) the extent to which federal 
agencies coordinate their transition activities. 

To identify potential challenges, we reviewed the definitions of 
disability and the eligibility criteria in selected federal statutes 
governing federal programs that provide transition services.[Footnote 
6] To assess the extent to which federal agencies coordinate their 
transition activities, we asked officials from the four agencies that 
administer key programs serving students in their transition out of 
high school--Education, the Departments of Health and Human Services 
(HHS) and Labor (Labor), and the Social Security Administration (SSA)--
to provide information on their coordination efforts and activities 
relating to transition services. We compared their responses and 
agency documents to our criteria on activities that can enhance and 
sustain collaboration among federal agencies.[Footnote 7] In addition, 
we consulted a number of experts in the field of transition and from 
advocacy organizations that represent young adults with a wide range 
of disability types. Finally, to obtain the perspectives of state and 
local agencies that deliver transition services, we selected a 
nongeneralizable sample of five states and contacted officials to 
obtain their views. We selected these states based on the number of 
federal grants they received in fiscal year (FY) 2011 to fund 
transition services, recommendations of agency officials and experts, 
and geographic diversity.[Footnote 8] Through a combination of site 
visits and telephone interviews, we spoke with service providers and 
officials from state education, vocational rehabilitation, 
developmental disability, and workforce agencies. In each state we 
visited, we also met with groups of students with disabilities and 
parents to discuss the challenges they face. Appendix I explains our 
scope and methodology in more detail. 

We conducted this performance audit from July 2011 through July 2012 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Background: 

To support the educational needs of children with disabilities, 
Congress originally enacted IDEA in 1975.[Footnote 9] Part B of IDEA 
authorizes federal funding for children aged 3 through 21 with a range 
of disabilities who need special education services. To receive 
federal funds, states and local education agencies must identify and 
evaluate children who have disabilities and provide special education 
and related services, as well as supplementary aids and services when 
necessary, to those who are eligible. Such services and supports are 
formulated in an IEP, which is developed, discussed, and documented by 
a student's IEP team.[Footnote 10] In the 2004 reauthorization of 
IDEA, Congress required that, beginning no later than age 16, a 
student's IEP must include measurable postsecondary goals related to 
training, education, employment, and where appropriate, independent 
living skills. The IEP also must specify the transition services 
[Footnote 11] needed to assist the student in reaching those goals. 
[Footnote 12] School officials are required to invite the student to a 
meeting where the transition services detailed in the IEP are 
discussed. When appropriate, they also must invite a representative of 
any participating outside agency (with the prior consent of the parent 
or student who has reached the age of majority).[Footnote 13] 

As students with disabilities exit high school, they may apply as 
adults and be found eligible for a number of federally funded 
programs, including federal disability programs, if they wish to 
obtain services important to their transition. There is wide diversity 
in this population--students with disabilities can have a range of 
physical and cognitive disabilities that can affect their ability to 
learn. They may also demonstrate varying levels of academic aptitude 
and achievement in different areas. Thus, the number of programs for 
which each student may be eligible can vary widely based on their 
abilities, postsecondary goals, and the types of supportive services 
they may need to be successful. We identified a range of programs that 
provide services to support students with disabilities in their 
transition out of high school. These programs vary in the target 
population served, services provided, grant funding amounts, and other 
characteristics. In addition, they are authorized by multiple federal 
laws (administered through various federal agencies), each with its 
own eligibility requirements and application processes. (See figure 
1). Moreover, federally funded programs that provide transition 
services, as defined in this report, are often delivered through state 
and local entities that have flexibility on how to administer services. 

Figure 1: Key Federal Legislation Providing for Services to Transition-
Age Students with Disabilities: 

[Refer to PDF for image: illustration] 

Assistive Technology Act of 1994: 
Examples of services provided: Assistive technology; 
Age: Prior to age 14 and beyond age 25. 

Developmental Disabilities Assistance and Bill of Rights Act of 2000: 
Examples of services provided: Activities that support employment and 
training; 
Age: Prior to age 14 and beyond age 25. 

Higher Education Act of 1965[A]: 
Examples of services provided: Academic enrichment; 
Age: Age 1t to beyond age 25. 

Individuals with Disabilities Education Act: 
Examples of services provided: Academic enrichment, assistive 
technology, transition planning, and vocational assessment and work 
experience; 
Age: Prior to age 14 to age 22. 

Rehabilitation Act of 1973: 
Examples of services provided: Assistive technology, employment 
services, and financial assistance for postsecondary education and 
training; 
Age: Prior to age 14 and beyond age 25. 

Social Security Act[B]: 
Examples of services provided: Employment and training services, 
financial assistance, independent living and assistance, and 
transportation; 
Age: Prior to age 14 and beyond age 25. 

Workforce Investment Act of 1998[C]: 
Examples of services provided: Employment and training services' 
Age: 14 through 25 and beyond. 

Source: GAO review of agency documentation, including postings and 
publications. 

[End of figure] 

[A] Services under the Higher Education Act of 1965, as amended by the 
Higher Education Opportunity Act, begin largely when a student enters 
postsecondary education. Pub.L. No. 110-315, sec. 709(2), §§ 766-769, 
122 Stat. 3078,3365-67 (codified at 20 U.S.C. §§ 1140f-1140i): 

[B] Students who meet certain criteria may receive SSI benefits prior 
to age 18; the Social Security Administration is statutorily required 
to redetermine the eligibility of all children receiving these 
benefits within one year of their 18th birthday. 42 U.S.C. § 
1382c(a)(3)(H)(iii). 

[C] Students who meet certain criteria may receive services through 
the Workforce Investment Act of 1998 (WIA) youth program between the 
ages of 14 and 21; services through the WIA adult program may begin at 
age 18. 29 U.S.C. § 2801(1) and (13). 

The following four agencies have primary responsibility for 
administering federal programs that can provide services to transition-
age youth with disabilities: 

* Education's Rehabilitation Services Administration awards funds to 
state vocational rehabilitation (VR) agencies in the form of matching 
grants to help individuals with disabilities prepare for and engage in 
gainful employment.[Footnote 14] VR programs require that an 
individualized plan for employment be developed for eligible students 
before they leave high school.[Footnote 15] Furthermore, if the 
student is receiving special education services, this plan must be 
coordinated with the student's IEP in terms of goals, objectives, and 
services. 

* Labor oversees the one-stop center system, a comprehensive workforce 
investment system created under the Workforce Investment Act of 1998 
(WIA) that brings together multiple federally funded employment and 
training programs that can help all eligible individuals seeking 
employment and training--including students with 
disabilities.[Footnote 16] Labor also administers the Disability 
Employment Initiative, which is designed to improve educational, 
training, and employment opportunities and outcomes for youth and 
adults with disabilities who are unemployed, underemployed, and/or 
receiving Social Security disability benefits. 

* SSA provides cash benefits to qualifying individuals with 
disabilities--including transition-age young adults--through its 
Disability Insurance and Supplemental Security Income (SSI) programs. 
[Footnote 17] SSA also administers the Ticket to Work program, which 
is designed to enable individuals with disabilities (who are receiving 
disability insurance or SSI benefits and are between the ages of 18 
and 64) to obtain services needed to find, enter, and retain 
employment. They obtain these services from providers such as VR 
agencies.[Footnote 18] 

* HHS's Centers for Medicare & Medicaid Services manages Medicaid, the 
joint federal-state health care financing program for qualifying low-
income individuals. Within the Medicaid program, states provide home 
and community-based services to individuals with certain types of 
disabilities--which may include young adults--who might otherwise be 
cared for in institutional settings.[Footnote 19] Because Medicaid 
usually does not cover home and community-based services, states must 
obtain a waiver to provide these services. Services provided in 
accordance with these waivers vary by state, are individualized, and 
may include, for example, case management, personal care attendants, 
or day or residential habilitation.[Footnote 20] 

In addition, these and other federal agencies fund a number of other 
programs through grants to states, localities, and nongovernmental 
organizations that may assist students and young adults during their 
transition from high school. Some of these grants explicitly target 
improving postsecondary outcomes for students with disabilities and 
others provide a range of support services such as assistive 
technology, information and referral, advocacy, transportation, 
leadership development, benefits counseling, and independent living 
services. (See appendix II for more information on federal programs 
that received federal funding in FY 2011 to provide transition 
services to students with disabilities.) 

Students with Disabilities Face Several Longstanding Challenges 
Accessing Federal Transition Services: 

Students with disabilities face several challenges accessing federally 
funded programs that can provide transition services as they leave 
high school for postsecondary education or the workforce. These 
include difficulty navigating multiple programs that are not always 
coordinated; possible delays in service as they wait to be served by 
adult programs; limited access to transition services; a lack of 
adequate information or awareness on the part of parents, students, 
and service providers of available programs that may provide 
transition services after high school; and a lack of preparedness for 
postsecondary education or employment. Prior GAO work identified many 
of these same challenges, which is indicative of the longstanding and 
persistent nature of the challenges facing students with disabilities 
as they transition out of high school.[Footnote 21] 

Difficulty Navigating Multiple Programs that Provide Transition 
Services: 

In each of the five states we contacted, state officials said it can 
be difficult for students with disabilities and their families to 
navigate the multiple federal programs that provide transition 
services.[Footnote 22] Some officials said that the shift from being 
automatically entitled to services under IDEA if identified as 
disabled while in high school to having to apply as adults and be 
found eligible for multiple programs after exiting high school is 
difficult for students and their parents to understand. (See figure 2). 

Figure 2: Students Move from Services Provided through Their High 
Schools to Services Delivered through Multiple Programs: 

[Refer to PDF for image: illustration] 

Student with disabilities: 

While in high school: 
Eligible student entitled to services until graduating or leaving high 
school[A]; 
Services supporting students with disabilities in transition: 
Academics; 
Assistive technology; 
Independent living skills; 
Job Training[C]; 
Transportation. 

After high school: 
Student must apply and be found eligible for services from individual 
programs: 

Education: Vocational rehabilitation and education services[D]: 
Academics; 
Assistive technology; 
Employment assistance[B]; 
Independent living skills; 
Job Training[C]; 
Transportation. 

HHS: Medicaid home and community-based services: 
Employment assistance[B]; 
Housing assistance; 
Independent living skills; 
Transportation. 

Labor: Employment and training services from WIA programs: 
Employment assistance[B]; 
Job Training[C]. 

SSA: Supplemental security income and disability insurance[E]: 
Financial assistance. 

Source: GAO analysis of agency documentation, including postings and 
publications. 

Note: Students may also receive services from other federal and 
nongovernmental programs. 

[A] States must identify, evaluate, and provide services to children 
with disabilities. Students with disabilities remain entitled to 
services until they graduate from high school with a regular high 
school diploma or exceed the earlier of age 21 or the eligibility age 
for a free appropriate public education under state law. While federal 
law authorizes students to receive a free appropriate public education 
up until age 22, eligibility for students aged 18-21 is determined by 
states. 20 U.S.C. § 1412(a)(1) and 34 C.F.R. § 300.102 (2011). 

[B] Includes job coaching, job placement, and supported employment. 

[C] Includes vocational assessment, vocational education, and work-
based experiences. 

[D] Students must disclose their disability to obtain services in 
college. 

[E] SSA is statutorily required to redetermine the eligibility of all 
children receiving SSI benefits within one year of their 18th 
birthday. 42 U.S.C. § 1382(a)(3)(H)(iii). 

[End of figure] 

Many of the stakeholders told us that a lack of coordination between 
programs was another key challenge for students with disabilities and/ 
or their families.[Footnote 23] For example, staff from a parent 
training and information Center in Minnesota said that it is very 
challenging for parents to navigate the system and coordinate 
resources for their children across programs. In their experience, 
none of the program officials coordinate with those from other 
programs to share information on clients. State officials suggested 
that a lack of coordination between programs often arises as early as 
during IEP transition planning meetings. IDEA requires high schools to 
invite, with parental or student consent, representatives from adult 
programs likely to be responsible for providing or paying for 
transition services to the student after high school, such as VR, to 
these meetings to the extent appropriate.[Footnote 24] These 
representatives, however, are not required to attend, and we heard 
that they are often not at the table for transition planning meetings. 
VR officials from one state acknowledged this, saying that while they 
try to attend transition planning meetings, it is not always possible 
because of resource and time constraints. Some of the stakeholders 
suggested that without the commitment of local leaders and service 
providers to coordinate services between high school and adult 
programs, there is little to no communication between programs, which 
can create difficulty for families trying to navigate across different 
programs. 

[Side bar: State efforts to coordinate services across programs: 

* Florida's "Project 10 Transition Education Network" helps school 
districts provide appropriate planning and timely transition services 
to assist students with disabilities in their transition to adulthood 
and to improve their academic success and post-school outcomes. One of 
the network's current focuses is on interagency collaboration, with 
the goal of improving collaboration between school districts and 
community agencies that provide transition services to young adults 
with disabilities. 

* Ten school districts in Maryland participate in the state's ongoing 
Seamless Transition Collaborative, which involves several state 
agencies and focuses specifically on the braiding of funds to provide 
seamless transitions from high school to employment and/or college. 
The braiding of funds involves bringing together multiple but separate 
funding streams to pay for more than any one stream can support, and 
then carefully pulling them back apart to report to funders on how the 
money was spent. 

* Minnesota's Department of Employment and Economic Development has 
placed VR counselors in some high schools and hosts an annual meeting 
with representatives from high schools to discuss VR's expectations 
for how it will be involved in transition planning and services for 
high school students. 

* A school district in California allows its high schools to contract 
with VR and SSA for transition-related services and has two VR 
counselors located in the schools. The district also participates in 
SSA's Ticket to Work program and is part of a state-wide initiative 
linking students with disabilities to work opportunities. 
End of side bar] 

In each of the five states we contacted, some officials said that 
differing requirements for adult programs can confuse students and 
parents. For example, officials from Florida's department of VR said 
that the requirement for VR clients to have an individualized plan for 
employment that identifies an employment goal and the services and 
supports necessary to achieve that goal can be confusing for youth who 
already included transition plans and identified a career goal in 
their IEP. In addition, the amount of documentation each program 
requires can be overwhelming for students with disabilities and their 
parents. According to a student in Maryland, there is a continuous 
administrative burden on applicants to provide the same or similar 
information to multiple programs. Officials we interviewed from three 
of the four federal agencies acknowledged these challenges. 

In each of the states we contacted, officials suggested that it would 
be helpful to appoint a case manager to coordinate services and guide 
students and their families through the transition process. Some of 
the parents and also officials from two of the four federal agencies 
agreed that a case manager could help students with disabilities and 
their families navigate across the multiple programs. However, 
officials from one federal agency cautioned that it could be costly 
and, given that programs that provide transition services are 
administered by different federal agencies and implemented at the 
state and local level, challenging to administer. 

Delays in Service: 

Students with disabilities may also face delays in service upon 
leaving high school as they wait to obtain services from adult 
programs or for their eligibility determinations to be finalized. Many 
stakeholders said that delays in service can be caused by limited 
financial or program resources, which may leave youth with 
disabilities on waitlists for services. In particular, states may have 
waitlists--sometimes with several thousand individuals--for home and 
community-based waiver services. The departments of VR in four of the 
five states we contacted were operating under a federally required 
order of selection, requiring them to serve individuals with the most 
significant disabilities before serving others.[Footnote 25] Several 
parents from Minnesota said that their children had been on waitlists 
for waiver services or VR services for years. One parent from Florida 
said that her adult son was living at home with no services or 
employment options as he waited for waiver services from the state's 
department of disability. Officials from Nevada's department of VR 
said that delays in service may also occur when students with 
disabilities, upon leaving high school, must return assistive 
technology devices on loan from the school, such as software for blind 
individuals that reads text on a screen in a computer-generated voice. 
According to officials, some students go without these critical 
adaptive devices until VR is able to equip them with the same or 
similar technologies. 

Service delays can be exacerbated if students with disabilities have 
to wait until program officials resolve who should provide and pay for 
services. In addition, some adult programs will not provide services 
to students who are still eligible to receive services under IDEA. 
[Footnote 26] Officials from two states said that, as a result, there 
has been a shift toward keeping students with disabilities in high 
school longer so that schools continue paying for services until 
students graduate or turn 22 years of age. For example, officials from 
Maryland's department of VR said that students with developmental 
disabilities who decide to leave high school before they age out of 
IDEA services often face a delay in services because the state 
department of developmental disability will not provide services to 
students younger than age 21.[Footnote 27] 

[Side bar: Aligning eligibility criteria and definitions of disability: 

In Nevada, the state Department of Special Education is working with 
the state higher education system to align their definition of 
disability, eligibility criteria, and documentation requirements to 
make the transition from high school to college easier and more 
seamless for students. End of side bar] 

Some of the stakeholders said that differing eligibility criteria, 
definitions of disability, and assessment requirements for the various 
adult programs can also result in service delays while youth with 
disabilities wait for assessments or eligibility determinations. For 
example, officials in the four states in which we spoke with higher 
education officials said some colleges require students with 
disabilities to be reassessed before they can receive accommodations, 
and that this can cause a delay in service because there are long 
waitlists for these reassessments or because they are cost prohibitive 
for some families. 

Limited Access to Transition Services: 

Limited access to reliable public transportation to and from 
employment programs and service providers--especially in rural areas--
was also frequently highlighted as a major challenge. For example, 
officials from Florida said limited funding for transportation 
services contributes to the lack of transportation for students with 
disabilities. 

Officials in each of the states we contacted also said that certain 
groups of students with disabilities are more likely to face limited 
service options or gaps in service because their disabilities may be 
less visible or because they are less likely to qualify for adult 
programs. These groups include students with developmental or 
cognitive disabilities, learning disabilities, mental health 
disabilities, autism, and mild disabilities. Further, we heard that 
there may be limited programs for students with hearing or visual 
impairments, and that if these students also have other disabilities, 
it can be difficult to determine which program (e.g., VR or a 
developmental disability agency) should provide services, which can 
lead to gaps in service. Similarly, officials said that students with 
disabilities who are in the juvenile justice system, are themselves 
parents, or are homeless may also be more likely to face gaps in 
service than other students with disabilities because they tend not to 
be aware of or connected to adult service providers. In addition, some 
students who qualified for services under IDEA and/or under Section 
504 of the Rehabilitation Act may not meet the eligibility 
requirements for adult programs and may, therefore, have limited or no 
post-high school service options. For example, one parent told us that 
her daughter, who has a serious physical disability, did not receive 
any transition planning assistance and struggled to gain access to 
services such as personal care attendants who would help her 
successfully transition to a college out of state. 

Lack of Adequate Information and Awareness of Options after High 
School: 

A lack of adequate information and awareness of available program 
options on the part of parents, students, and service providers was 
another challenge highlighted during our site visits. Many 
stakeholders said that students with disabilities and their parents do 
not always receive enough information about the full range of service 
options after high school. For example, a parent from California said 
that she was very disappointed with the limited information she 
received from her school district and that she had no idea what 
resources were available for her son after he left high school. A 
student from Maryland expressed concern that students with 
disabilities who do not seek information about transition services 
outside of high school may not have access to information, and 
consequently, to needed services. In contrast, a few stakeholders said 
parents may receive too much information and feel overwhelmed. For 
example, a parent from California said that families may receive so 
much information that they do not remember everything and do not know 
where to seek help when the time comes. A staff member from the 
California Department of Education's Workability program said that, 
even when information about transition services is available, it is 
generally not compiled and made available in one central place for 
families to access.[Footnote 28] She recommended that states or 
programs develop an accessible, easy to read transition manual that 
clearly lays out post-high school service options. 

[Side bar: Centralized information about transition service options: 

* Maryland's Department of Education, developed a "Transition Planning 
Guide", designed to provide students with disabilities and their 
families with easily understandable and accessible information about 
transition services and options. 

* One of the parent training and information centers in Minnesota 
developed an online resource mapping tool to help families identify
services within their community that their children might be eligible 
for based on where they live. End of side bar] 

Sometimes there was an issue with the accuracy of information parents 
received. For example, officials in three of the five states we 
contacted said that parents may be misinformed about programs, 
especially about the ability of their children to retain SSI benefits. 
Officials from Florida's developmental disability agency noted that 
parents are often misinformed by teachers or adult program service 
providers that their children will lose these benefits entirely if 
they obtain any paid employment. 

Lack of awareness of service options also extended to teachers and 
other high school personnel. Many of the stakeholders said that 
teachers and other high school personnel may not always be aware of 
post-high school service options for students with disabilities. For 
example, one parent said that while there are a lot of programs in her 
community that can aid students in transition, school personnel are 
not aware of them and therefore cannot appropriately guide students 
with disabilities and their families. Moreover, some experts and state 
education officials said that teacher training and professional 
development programs do not always adequately prepare teachers to 
provide transition services or inform them about the various agencies 
and resources available to students with disabilities. A few of the 
officials, however, said that teachers in some school districts are 
well trained in and aware of adult programs that can provide 
transition services, which allows them to disseminate information to 
students and their parents. 

In addition, some stakeholders said that service providers from adult 
programs may not be used to working with this student population or 
have limited awareness of other adult programs that can provide 
complementary transition services. For example, stakeholders in 
Maryland and Nevada said that VR counselors need additional training 
to work with transition-age youth with disabilities and officials from 
Maryland's local workforce agencies said that one-stop center staff 
need more training to help these students enter the workforce. A 
representative from a parent training and information center in 
Maryland added that the knowledge service providers have about other 
programs is piecemeal and inconsistent. She suggested the federal 
government support additional training for all professionals who work 
with students in transition. 

Inadequate Preparation for Postsecondary Education or the Workforce: 

Many stakeholders said that high schools do not always adequately 
prepare students with disabilities for college or the workforce, and 
cited several contributing factors. According to some officials, the 
federal requirement to begin transition planning by age 16 is too 
late. In fact, officials in four of the five states we contacted said 
that schools are required to start transition planning at an earlier 
age.[Footnote 29] In addition, in all five states we heard that 
schools' emphasis on academic achievement has left little time for 
vocational and life skills training, even though these skills may be 
key to gaining and retaining employment--especially for students with 
disabilities. Officials from Minnesota's department of VR said that 
schools need to pay greater attention to vocational training because 
students with disabilities are at a distinct disadvantage if they 
leave high school with no work experience. Further, officials from 
Maryland's department of developmental disabilities said that because 
most jobs require a high school diploma, students with disabilities 
who receive certificates instead of diplomas could find their 
employment options significantly curtailed because many employers do 
not recognize alternative completion documents.[Footnote 30] As a 
transition specialist from Maryland noted, many students with non-
traditional diplomas end up in sheltered workshops because they are 
not considered to be qualified for competitive employment 
opportunities.[Footnote 31] 

[Side bar: State efforts to address lack of preparedness: 

* Florida's High School High Tech program, a community-based 
partnership made up of students, families, businesses, educators, and 
rehabilitation professionals, and jointly funded through a non-profit 
organization and the state Department of Education, Division of
Vocational Rehabilitation, is designed to provide students with all 
types of disabilities with the opportunity to explore jobs or college 
experiences that could lead to careers in technology. 

* California's Workability program is a school-based work program for 
students with disabilities, and coordinates services among the state 
Departments of Employment Development, Education, and Rehabilitation.
This program offers special education students the opportunity to 
complete high school while obtaining marketable job skills. It is 
designed to provide comprehensive pre-employment training, employment 
placement, and follow-up for high school students in special education 
who are making the transition from school to work, independent living, 
and college or training. End of side bar] 

In addition, according to some stakeholders, adult programs are not 
always designed to meet the needs of transition-age youth with 
disabilities in ways that will help them succeed in college or in a 
job. For example, a few state officials said that the VR system does 
not provide incentives for serving transition-age youth with 
disabilities because VR's performance indicators reward counselors for 
serving clients who find and maintain employment for at least 90 days, 
and youth with disabilities may take longer to do so.[Footnote 32] 
Similarly, we heard from a few officials, including representatives 
from California's workforce agency, that the time frame of the 
employment outcome measures under the WIA youth program may be too 
short--for example, the employment retention rate at 6 months[Footnote 
33]--and not appropriate for transition-age youth with disabilities 
who often require follow-up support longer than 6 months in order to 
be successful at a job.[Footnote 34] 

Another frequently mentioned challenge was low expectations by 
parents, service providers, and even students themselves about what 
students with disabilities can achieve. These groups told us that low 
expectations often contributed to students with disabilities being 
unprepared for college or the workforce because parents, teachers, and 
others may not have exposed them to all available options for life 
after high school. Consequently, some officials said students may be 
directed to apply for social security benefits instead of receiving 
job training, and that students with more serious disabilities who 
could benefit from competitive employment (i.e., applying for and 
getting a job) may be steered instead toward adult day training 
programs and sheltered workshops. 

Federal Agency Coordination of Transition Activities Has Limitations: 

Federal Agencies Coordinate On Specific Transition Activities But Face 
Some Barriers: 

Education, HHS, Labor, and SSA coordinate transition activities to 
some degree, but their coordination has limitations and they do not 
assess the effectiveness of their efforts. They coordinate on some 
specific transition activities, but their efforts are primarily 
focused on information sharing and lack elements that our prior work 
identified as enhancing and sustaining effective coordination. 
[Footnote 35] We have reported on the importance of developing common 
outcome goals and of engaging in strategic planning and coordination 
to address issues that cut across agency boundaries. This can take 
many forms, ranging from occasional meetings between agency staff to 
more structured joint policy teams operating over a long period of 
time.[Footnote 36] 

One federal coordination effort--the Federal Partners in Transition 
Workgroup--targets transition services to students with disabilities 
and involves all four agencies that administer the key programs that 
provide transition services to youth with disabilities.[Footnote 37] 
However, this workgroup is informal and primarily involves information 
sharing among staff-level representatives, according to agency 
officials. For example, SSA officials told us that in past meetings, 
their staff presented information about SSI requirements for the 
transitioning youth population, including the process for 
redetermining eligibility for SSI when youth turn age 18, and 
information on the Student Earned Income Exclusion.[Footnote 38] To a 
lesser extent, some workgroup members also reported that they have 
jointly developed guidance for students with disabilities and 
grantees, including a fact sheet about how students can take advantage 
of Schedule A hiring authority for federal jobs.[Footnote 39] In 
addition, the workgroup has convened forums to help students with 
disabilities develop their leadership and self-advocacy skills and to 
discuss action steps to ensure students are prepared to move 
successfully to adulthood. This workgroup also convened a meeting of 
representatives of technical assistance centers to discuss 
coordination among the centers. Agencies involved in the workgroup 
reported varying levels of involvement in more extensive coordination 
activities, such as policymaking, program planning, and joint 
strategic planning. Labor officials leading the effort told us they 
are in the process of drafting a strategic plan to identify 
objectives, activities, and outcomes for the group. 

Education and Labor also participate in the National Community of 
Practice in Support of Transition, which was developed by the IDEA 
Partnership and focuses on joint efforts among state and local 
agencies to coordinate and improve outcomes for youth with 
disabilities in transition. Both agencies also have established intra-
agency groups to facilitate collaboration between internal program 
offices.[Footnote 40] (See figure 3.) Education officials also said 
they recently sponsored a national transition conference for more than 
800 professionals, families, and students to facilitate collaboration 
and communication across federal, state, and local entities. Aside 
from these efforts, officials said most of their interagency 
coordination regarding transition services occurs on an ad hoc basis, 
such as sharing white papers and holding informal discussions about 
policies, performance measures, and technical assistance to states. In 
addition, several federal coordination efforts broadly target 
disadvantaged youth or all individuals with disabilities and may 
address some aspects of transition. (See appendix III). 

Figure 3: Federal Coordination Efforts Specific to Transition Services: 

[Refer to PDF for image: illustrated table] 

Name and purpose of effort: Federal Partners in Transition Workgroup: 
Promote youth service delivery systems to assist youth with 
disabilities transition to postsecondary education or employment; 
Education: Agency is involved in the effort
HHS: Agency is involved in the effort; 
Labor: Agency leads effort; 
SSA: Agency is involved in the effort; 
Key activities coordinated: Policymaking, guidance to federal 
grantees, program planning, and information exchange through databases 
and websites; 
Mechanisms of coordination: Interagency meetings, regular information 
sharing. 

Name and purpose of effort: IDEA Partnership National Community of 
Practice in Support of Transition: Improve interagency transition 
initiatives and promote the role of youth in the transition process 
through providing technical assistance to service providers, youth, 
and families;  
Education: Agency leads effort; 
Labor: Agency is involved in the effort; 
Key activities coordinated: Standards and practices, guidance to 
grantees and beneficiaries, program planning, information exchange 
through databases and websites; 
Mechanisms of coordination: Interagency meetings, regular information 
sharing, cross-training of staff, joint training of grantees, joint 
information sessions for beneficiaries. 

Name and purpose of effort: Office of Special Education and 
Rehabilitative Services Transition Steering Committee: Facilitate 
collaboration between offices within the Office of Special Education 
and Rehabilitative Services, federal partners, and other stakeholders 
to improve outcomes for transitioning youth with disabilities; 
Education: Intra-agency effort; 
Key activities coordinated: Guidance to grantees and beneficiaries, 
program planning, information exchange through databases and websites; 
Mechanisms of coordination: Common policies, intra-agency meetings, 
joint strategic planning, regular information sharing, intra-agency or 
shared databases, co-location and cross-training of staff, joint 
training of grantees, joint information sessions for beneficiaries, 
joint evaluations and reports. 

Name and purpose of effort: Youth with Disabilities Work Group: Assist 
public workforce development systems to expand capacity to serve youth 
with disabilities and develop guidance to increase the percentage of 
youth with disabilities who receive diplomas and certificates, and 
achieve other education and employment objectives; 
Labor: Intra-agency effort; 
Key activities coordinated: Guidance to grantees and beneficiaries, 
program planning; 
Mechanisms of coordination: Intra-agency meetings, regular information 
sharing, joint training of grantees, joint information sessions for 
beneficiaries. 

Source: GAO analysis of information provided by agency officials. 

Note: While some coordination efforts included in this figure involve 
other federal agencies, we focused on Education, HHS, Labor, and SSA 
because they administer the key programs serving students in their 
transition out of high school. Key activities coordinated and 
mechanisms of coordination were reported by at least half of the 
reporting member agencies. For efforts with two key member agencies, 
only mechanisms and activities reported by both agencies were included. 

[End of figure] 

Some federal agencies are involved in new demonstration projects that 
plan to address coordination across systems at the state and local 
level. For example, an official from HHS stated that the agency has 
coordinated with Education and Labor to develop grants under the new 
Projects of National Significance Partnerships in Employment Systems 
Change. This initiative will provide resources for state agencies and 
service providers to collaborate with other services systems to 
develop statewide model demonstration projects that expand competitive 
employment for youth with developmental disabilities. In another 
example, officials at all four agencies said they have been involved 
in early discussions regarding implementation of the new Promoting 
Readiness of Minors in Supplemental Security Income (PROMISE) 
initiative, which will fund pilot projects in states to promote 
positive changes in the outcomes of youth SSI recipients and their 
families.[Footnote 41] Education officials said they are in the 
process of holding meetings to gather input on potential projects from 
federal partners and stakeholders, including state agency officials, 
service providers, researchers, policy experts, and families. As part 
of the initiative, Education and SSA officials said they will work 
collaboratively to identify legislative barriers to competitive 
employment and ways to improve coordination at the state level. In 
addition to collaborative efforts across agencies, Education officials 
said that six grants focusing on transition and funded by their 
Rehabilitation Services Administration are in their fifth and final 
year of operation. According to Education officials, these grants 
demonstrate the use of promising practices of collaborative transition 
planning and service delivery to improve the postsecondary education 
and employment outcomes of youth with disabilities. 

Despite these efforts, federal agency officials identified several 
barriers that limit their ability to coordinate. We have reported that 
federal agencies face a range of coordination barriers, one of which 
stems from goals that are not mutually reinforcing or are potentially 
conflicting, making it difficult to reach a consensus on strategies 
and priorities.[Footnote 42] We found interagency coordination is 
enhanced by having a clear and compelling rationale for staff to work 
across agency lines and articulate the common federal outcomes they 
are seeking.[Footnote 43] Indeed, officials identified a lack of 
compatible outcome goals for transitioning students with disabilities 
as one of the key barriers that hinder their coordination efforts. 

The incompatibility in outcome goals is highlighted in the 
implementation of specific programs, according to agency officials. 
For example, goals for employment outcomes in VR and workforce 
programs are in some cases countered by requirements for students to 
prove that their disabilities limit their ability to work in order to 
receive SSI benefits.[Footnote 44] Similarly, officials told us that, 
in early interagency discussions regarding the PROMISE initiative, 
special education officials focused on students' access to 
postsecondary education, while VR and SSA officials were more 
concerned about students' earnings. Officials from all four agencies 
said that aligning outcome goals for transition-age students with 
disabilities would enhance interagency coordination and help agencies 
approach transition in a more integrated way. Some officials suggested 
establishing a common agreement on desired outcomes for transitioning 
students, such as economic self-sufficiency or engagement in 
meaningful employment, volunteer work, or postsecondary education by a 
certain age. 

Differences in statutory eligibility criteria among programs also 
limit federal agencies' ability to coordinate, according to agency 
officials. For example, one official said that special education and 
SSI programs, in effect, have different legal definitions of "child" 
[Footnote 45] and "transition services,"[Footnote 46] making it more 
difficult to identify potential service recipients across programs and 
to share data about individuals served by multiple programs.[Footnote 
47] As a result, agencies are limited in their ability to target 
services to recipients who might benefit from them. Moreover, 
integrating information about students served by multiple programs 
over time would allow agencies to assess the impact of transition 
services across programs, according to Education and SSA officials. In 
addition, officials said sharing information about common service 
recipients would help agencies serve students with disabilities in a 
more streamlined way. For instance, SSA could identify students 
receiving employment and training services through other federal 
programs and provide counseling to help them understand how paid 
employment affects their SSI benefits and health insurance, with an 
eye toward helping students attain greater economic self-sufficiency. 
Officials cautioned, however, that privacy concerns may limit some 
information sharing and make it difficult to integrate information 
from multiple systems. While officials noted that the Federal Partners 
in Transition Workgroup has discussed these information sharing 
challenges at some of its meetings, one official noted that there is 
no substantive effort to address them at the federal level. 

Officials also identified a lack of clarity on agencies' roles and 
responsibilities for providing and paying for transition services as 
another coordination barrier. For example, each program has its own 
statutory authority, permitting it to pay only for certain services or 
types of services. This can create confusion, particularly at the 
state and local levels, about who is responsible for paying for a 
particular service. It can also result in frequent debates about which 
agency is responsible for funding services, according to some 
officials, creating a disincentive for agencies to work together. 
While certain state agencies such as educational agencies and VR 
agencies are required to articulate roles and responsibilities in 
interagency agreements,[Footnote 48] Education officials suggested 
that a program's authorizing statute should clearly define agency 
responsibilities to help avoid confusion and minimize potential delays 
and disruptions in delivering transition services. 

Agencies Lack A Government-Wide Strategy or Framework for Coordinating 
Transition Services: 

Although federal agencies are engaged in some coordination efforts, 
these efforts represent a patchwork approach and officials at all four 
agencies indicated there is no single, formal, government-wide 
strategy for coordinating transition services. While such a strategy 
is not required, we have previously cited the need for an overall 
federal strategy and government-wide coordination to align policies, 
services, and supports among the various disability programs, which 
include supports for transition-age students.[Footnote 49] Agency 
officials acknowledged that coordination specifically on transition 
services could be improved. For example, one official said agencies 
could work collaboratively to identify opportunities to address 
legislative and regulatory barriers to coordinating transition 
services. Officials added that improved data collection and sharing 
could help agencies adopt a more coordinated and crosscutting approach 
to delivering transition services to students with disabilities. Labor 
officials leading the Federal Partners in Transition Workgroup said 
that, while an overall plan for transition remains beyond the group's 
scope of work, a framework that identifies what is needed for a 
successful transition could be used at the federal level to review 
collaboration across systems and to identify definition, service, and 
funding gaps.[Footnote 50] Such a framework could also be used at the 
local level to identify gaps in communities and individual plans. 

Federal Agencies Do Not Assess The Effectiveness of Their Coordination 
Efforts: 

It is unclear whether existing federal coordination efforts have had a 
positive effect on access to transition services because agencies do 
not assess their coordination efforts. We have reported that 
developing mechanisms to monitor, evaluate, and report on the results 
of their coordination efforts can help key decision makers within 
agencies, as well as clients and stakeholders, obtain feedback for 
improving both policy and operational effectiveness. For example, 
coordinating agencies could require members with lead responsibilities 
for a focus area to report on their progress in achieving defined 
objectives.[Footnote 51] Federal officials said that coordination has 
helped improve relationships and communication across agencies 
administering transition services, yielding an increased understanding 
of each other's research, policy, and evidence-based practices as a 
result of their involvement in interagency efforts, including the 
Federal Partners in Transition Workgroup. Agency officials also told 
us that some coordination efforts have led to increased engagement in 
transition policy by students with disabilities and their families and 
improved results in achieving career readiness and self-sufficiency. 
However, these results are difficult to corroborate because agencies 
do not evaluate the impact of their efforts, and in many cases do not 
track coordination outcomes at the federal level, according to agency 
officials.[Footnote 52] Furthermore, the effectiveness of existing 
federal coordination efforts is questionable, as evidenced by 
persistent challenges students with disabilities face navigating 
multiple programs. 

Some federal agencies monitor compliance with requirements for 
grantees to coordinate with other state and local entities under 
individual programs. For example, Part B of IDEA requires state 
educational agencies to report annually on their performance using 20 
indicators established by the Secretary.[Footnote 53] One of the 
indicators measures the state's compliance with the requirement under 
IDEA to include postsecondary goals and transition services in the 
IEPs of students age 16 and above; and to invite the student and, if 
appropriate, representatives from other participating state agencies 
to the student's IEP team meetings if transition services are to be 
discussed.[Footnote 54] Similarly, state VR agencies must report 
annually to the Rehabilitation Services Administration on whether they 
have identified the responsibilities of other agencies through 
statute, regulation, or written agreements, and to undergo monitoring 
of their coordination activities.[Footnote 55] These monitoring 
reviews, however, mainly address compliance with programmatic and 
fiscal requirements, help ascertain whether state agencies have in 
place signed formal interagency agreements, and check whether these 
agreements include key components such as providing technical 
assistance to school districts on transition planning. Agency 
officials noted that there are no quantifiable measures to assess how 
effectively transition services are coordinated, and that any 
assessment is typically based on observation and a review of practices 
and procedures rather than on data.[Footnote 56] 

Conclusions: 

The current federal approach to assisting students with disabilities 
in their transition to postsecondary education or the workforce 
necessitates that students and their parents navigate multiple 
programs and service systems to piece together the supports these 
students need to achieve maximum independence in adulthood. Under this 
complex structure, information dissemination and service coordination 
are essential. Without receiving accurate and timely information about 
available services, students may miss opportunities to access needed 
services that could mean the difference between achieving an optimal 
level of self-sufficiency and relying on public assistance to meet 
their basic needs. While officials report that federal agency 
coordination efforts, such as the Federal Partners in Transition 
Workgroup, have improved relationships and built shared knowledge 
across participating agencies, they have yet to adopt a broader 
interagency strategic approach to addressing longstanding challenges 
in providing transition services to students with disabilities. The 
transition workgroup, in particular, represents a unique vehicle that 
could provide leadership in developing such a strategy specifically 
focused on students with disabilities who are transitioning out of 
high school. Given the multiple agencies involved in supporting this 
population, in conjunction with multiple eligibility criteria and 
definitions established in statute, the lack of such a strategy is a 
missed opportunity to break down coordination barriers and work across 
agency boundaries. Only then can agencies systemically address 
persistent transition challenges and improve outcomes for students 
with disabilities. Furthermore, without assessing the effectiveness of 
federal coordination efforts, agencies are unable to determine what 
works well, what needs improvement, and where best to direct 
increasingly constrained federal resources. 

Recommendation for Executive Action: 

To improve the provision of transition services to students with 
disabilities through enhanced coordination among the multiple federal 
programs that support this population, we recommend that the 
Secretaries of Education, HHS, and Labor, and the Commissioner of SSA 
direct the appropriate program offices to work collaboratively to 
develop a federal interagency transition strategy. This strategy 
should address: 

1. compatible policies, procedures, and other means to operate across 
agency boundaries towards common outcomes for transitioning youth and 
their families; 

2. methods to increase awareness among students, families, high school 
teachers, and other service providers on the range of available 
transition services; and: 

3. ways to assess the effectiveness of federal coordination efforts in 
providing transition services. 

To the extent that legislative changes are needed to facilitate the 
implementation of this transition strategy, agencies should identify 
and communicate them to the Congress. 

Agency Comment and Our Evaluation: 

We provided a draft of this report to officials at the Departments of 
Education, HHS, and Labor, and to SSA for their review and comment. 
Their responses are reprinted, respectively, in appendixes IV, V, VI, 
and VII of this report. They also provided technical comments, which 
we incorporated as appropriate. 

In their comments, all four agencies agreed with our recommendation 
and noted that they have been or will be in contact with each other to 
expedite preliminary discussions on an implementation strategy. 

Some of the agencies also described coordination efforts beyond those 
mentioned in our draft report. Specifically, Education said it is 
currently engaged in numerous transition coordinating activities with 
HHS, Labor, and SSA related to discretionary grants, legislative 
proposals, draft regulations, policy positions, and program 
improvements. Education highlighted the National Transition Conference 
it hosted in May 2012, explaining that the four agencies worked 
together to plan and participate in all stages of the conference with 
the goals of raising awareness of services, sharing promising 
practices, and creating an action agenda to improve transition 
outcomes for youth with disabilities. 

HHS noted that it funds the Consortium to Enhance Postsecondary 
Education for Individuals with Developmental Disabilities. This 
consortium conducts research, provides training and technical 
assistance, and disseminates information on promising practices that 
support individuals with developmental disabilities to increase their 
independence, productivity and inclusion through access to 
postsecondary education. Since 2010, HHS has also collaborated with 
Education and Labor on Project SEARCH, a program to support local 
students with disabilities in their last year of high school to 
experience work opportunities within these federal agencies. 

Labor stated that it plans to reach out to Education and SSA to 
explore ways to formalize its Federal Partners in Transition 
Workgroup. This group will work to help align policies, services, and 
supports provided by various programs to transition-age youth with 
disabilities, and to help identify legislative and regulatory barriers 
that prevent the coordination of transition services. Moreover, this 
group would assess the impact of its coordination efforts by 
developing common outcome goals. 

Finally, HHS noted that the Developmental Disabilities Assistance and 
Bill of Rights Act of 2000 does not provide for direct transition 
services. In response, we clarified, in figure 1, that the act 
provides funding for activities that support employment and training 
for youth with disabilities. HHS also questioned the relevance of 
several programs included in our list of federal programs that provide 
transition services, on the basis that the programs do not provide 
direct services. We agree that one of these programs, Partnership in 
Employment Systems Change Grants, is intended to enhance collaboration 
rather than provide transition services; therefore, we removed it from 
the list. However, we disagreed that the Youth Information, Training 
and Resources Centers program be omitted from the list. It provides 
self-advocacy services that we consider to be a type of transition 
service for youth. Similarly, we disagreed that Developmental 
Disabilities Protection and Advocacy should be omitted from the list. 
This program provides information on transition services and supports 
to youth, among other things. Consequently, both programs are still 
included. 

As agreed with your office, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies of this report 
to the Secretaries of Education, HHS, and Labor, as well as the 
Commissioner of SSA, and other interested parties. In addition, the 
report will be available at no charge on our website at: [hyperlink, 
http://www.gao.gov]. 

If you or your staff have any questions concerning this report, please 
contact me at (202) 512-7215 or moranr@gao.gov. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this report. Key contributors to this report are 
listed in appendix VIII. 

Sincerely yours, 

Signed by: 

Revae Moran: 
Director, Education, Workforce and Income Security Issues: 

[End of section] 

Appendix I: Scope and Methodology: 

Our review examined the (1) challenges students with disabilities may 
face accessing federally funded transition services; and (2) extent to 
which federal agencies coordinate their transition activities. To 
determine the challenges students with disabilities may face accessing 
transition services as they leave high school for postsecondary 
education or the workforce, we selected a nongeneralizable sample of 
five states and interviewed state and local officials responsible for 
administering the key federal programs that provide transition 
services. We visited four states: California, Florida, Maryland, and 
Minnesota, and interviewed officials in Nevada by phone. In the four 
states we visited, we also met with groups of parents and students 
with disabilities to discuss the challenges they face. In addition, we 
met with a number of experts in the field of transition and with 
associations representing young adults with a wide range of disability 
types to obtain their perspectives on challenges students face during 
transition. Finally, we reviewed the definitions of disability and the 
eligibility criteria in selected federal statutes that govern relevant 
federal programs providing transition services to identify any 
potential legislative or regulatory challenges they may pose. 

To assess the extent to which the four key federal agencies that 
administer programs providing transition services--the Departments of 
Education (Education), Health and Human Services (HHS), and Labor 
(Labor), and the Social Security Administration (SSA)--coordinate 
their transition activities, we interviewed agency officials, obtained 
their written responses to questions about their coordination efforts, 
and reviewed agency documents. We analyzed this information based on 
GAO criteria detailing activities that can enhance and sustain 
collaboration among federal agencies. We conducted this performance 
audit from July 2011 to July 2012 in accordance with generally 
accepted governmental auditing standards. Those standards require that 
we plan and perform the audit to obtain sufficient, appropriate 
evidence to provide a reasonable basis for our findings and 
conclusions based on our audit objectives. We believe that the 
evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 

We selected the five states in our nongeneralizable sample based on 
the number of grants each state received under key federal programs 
that provide transition services, recommendations from agency 
officials and experts, and geographic diversity, to the extent 
possible. To identify these key federal programs that provide grants 
to states and localities for transition services, we searched the 
Catalog of Federal Domestic Assistance (CFDA)[Footnote 57] and asked 
relevant agency officials to verify this list of programs and identify 
any programs that were not captured in our search results. Based on 
this search, we identified six federal grant programs that had a 
specific focus on improving transition services, and we looked at the 
distribution of grants to select states that received a relatively 
high number of federal grants for transition services.[Footnote 58] We 
also asked agency officials and experts for their recommendations of 
states with model programs or promising practices related to 
transition services and/or state-level collaborative efforts to 
improve transition outcomes. We did not do an independent legal 
analysis to verify program information from the CFDA or agency 
officials. To identify what additional challenges, if any, students 
may face in states with relatively few programs that provide 
transition services, we also selected one state with relatively few 
federal grant programs to determine if the key challenges identified 
were similar to those in other states. 

In each state we visited, we met with officials from state departments 
of education or special education, higher education, vocational 
rehabilitation, developmental disabilities, workforce 
agencies,[Footnote 59] and staff from parent training and information 
centers.[Footnote 60] In addition, with the exception of Nevada, staff 
from parent training and information centers in each state assisted us 
by organizing discussion groups with parents and students with 
disabilities that were in the process of planning their transition 
from high school to postsecondary education or employment or had 
recently made the transition out of high school. In a few states, we 
also met with officials from centers for independent living, other 
nongovernmental organizations that received federal grants to provide 
transition services, and transition specialists and experts. See table 
1 for a complete list of the organizations and groups we interviewed. 
During our interviews, we discussed challenges students with 
disabilities may face--including legislative or administrative 
barriers, potential gaps in transition services, knowledge of teachers 
and other service providers about transition services and options, 
parent and student awareness of available transition services and 
options, and coordination among federal agencies providing transition 
services. Finally, we asked officials from the relevant Education, 
HHS, Labor, and SSA program offices for their perspectives on the 
challenges faced by transitioning students with disabilities. 

Table 1: Organizations Contacted: 

Stakeholder: 
Organizations and groups interviewed: 

Stakeholder: California; 
State Departments of Education, Rehabilitation, Developmental 
Services, and Employment Development; State Council on Developmental 
Disabilities; a Workforce Investment Act One-stop Center; the State 
Foundation for Independent Living Centers; the State Transition 
Leadership Team and Transition specialists, experts, and coordinators; 
representatives from Higher Education groups and institutions; 
representatives from the State Workability Program; representatives 
from two Parent Training and Information Centers; and parents of and 
students with disabilities. 

Stakeholder: Florida; 
State Department of Education, Bureau of Exceptional Students and 
Divisions of Vocational Rehabilitation and Blind Services; State 
agencies for Persons with Disabilities and Workforce Innovation; 
Transitions specialists and coordinators; representatives from a 
Parent Training and Information Center; representative from three non-
profit organizations serving transition-age youth; and parents of and 
students with disabilities. 

Stakeholder: Minnesota; 
State Departments of Special Education, Human Services, and Employment 
and Economic Development, including the State Services for the Blind; 
Special Education Directors; a representative from a National Center 
on Secondary Education and Transition; representatives from higher 
education groups and institutions; representatives from one Parent 
Training and Information Center; representatives from one non-profit 
organization serving transition-age youth; and parents of and students 
with disabilities. 

Stakeholder: Maryland; 
State Departments of Education, Divisions of Special Education and 
Rehabilitation Services, and Disabilities; the State Developmental 
Disability Administration; the State Higher Education Commission; 
representatives from one Parent Training and Information Center; 
representatives from one non-profit organization serving transition-
age youth; several local workforce agencies[A] ; and parents of and 
students with disabilities. 

Stakeholder: Nevada; 
State Departments of Special Education and Vocational Rehabilitation; 
and representatives from one Parent Training and Information Center. 

Stakeholder: Subject matter experts and Associations; 
We spoke with 13 experts or groups that focus on transition, including 
groups representing students with developmental disabilities, students 
who are deaf or hard of hearing, students with learning disabilities, 
and students with intellectual and significant developmental 
disabilities. 

Stakeholder: Federal agencies; 
Education: Office of Special Education Programs; Rehabilitation 
Services Administration; and the Office of Postsecondary Education; 
Labor: Office of Disability Employment Policy; and Employment and 
Training Administration; HHS: Administration on Developmental 
Disabilities; and Centers for Medicare and Medicaid Services; SSA: 
Office of the Deputy Commissioner, Retirement and Disability Policy. 

Source: GAO. 

[A] We received written responses to our interview questions from some 
of Maryland's local workforce agencies, but did not speak with them in 
person. 

[End of table] 

To supplement the information collected during our interviews, we 
reviewed written responses and documents provided by officials from 
state and local organizations; reviewed selected statutory language 
related to some of the main legislative challenges identified by 
federal, state and local officials; and conducted a limited literature 
review of recent research related to transition challenges. 

To evaluate the extent to which federal agencies coordinate their 
transition activities, we asked officials from Education, HHS, Labor, 
and SSA to complete a data collection instrument we developed that 
requested information on their coordination efforts and activities 
relating to transition services. We reviewed agency officials' written 
responses to determine whether their efforts were formal or informal, 
targeted towards transitioning students with disabilities, which 
agencies were involved, and which specific activities were 
coordinated. We also interviewed agency officials from relevant 
program offices at each agency to obtain additional information about 
ongoing coordination efforts related to transition services. These 
interviews also addressed inter-and intra-agency coordination efforts 
related to transitioning students with disabilities, examples of 
successful outcomes from these coordination efforts, any agency 
assessments of their coordination efforts, and potential barriers to 
coordination. In addition, we reviewed and analyzed available 
documents from each agency, including their strategic plans, 
performance reports, and agency performance measures; program websites 
and descriptions; and other relevant agency documents, such as joint 
technical guidance. We assessed the extent of the agency's 
coordination efforts based on GAO's criteria for practices agencies 
can use to help enhance and sustain interagency collaboration. 
[Footnote 61] 

To provide an overview of federal programs that provide transition 
services to youth with disabilities, we identified 21 such programs 
administered by five federal agencies: Education, HHS, the Department 
of Justice, Labor, and SSA.[Footnote 62] (See appendix II). To 
identify these programs, we first searched the CFDA using key subject 
terms related to transition services for students with disabilities. 
[Footnote 63] This search produced a preliminary list of programs that 
was reviewed independently by two analysts. Each analyst reviewed the 
program descriptions in CFDA and from the relevant program websites, 
as necessary, and independently determined whether a program should be 
excluded due to clear lack of relevance to transition services for 
students with disabilities. The analysts then compared and discussed 
their decisions to further refine the list of programs. 

From this second list, we selected programs that met the following 
criteria: they (1) exclusively serve individuals with disabilities, 
including students of transition-age (age 14 to 25); (2) provide 
transition services directly to youth going from high school to 
postsecondary education or the workforce and/or services to their 
families; and (3) received federal funding in fiscal year 2011. 

We determined CFDA was sufficiently reliable for our purposes by 
confirming with federal agency officials that the programs identified 
met our criteria and obtaining information from agencies about any 
additional programs for our consideration. Specifically, we asked 
officials to correct any information we obtained from CFDA and program 
websites, identify any programs meeting our selection criteria that 
were not included in our search results, and provide additional 
information on the selected programs.[Footnote 64] We followed up with 
agency officials through teleconferences and email, as necessary, to 
clarify program information and make a decision to include or exclude 
programs. We reviewed agency documentation and selected laws and 
regulations to verify eligibility criteria, including definitions of 
disability and funding information. To assess the reliability of 
recipient data reported in our tables, we reviewed agency officials' 
responses to questions regarding how they collected the data, any 
potential limitations of the data, and the databases and systems used 
to maintain the information on program recipients. To assess the 
reliability of funding data, we reviewed publicly available and agency-
provided budget documents. In cases where funding amounts for specific 
programs were not separately reported, we clarified the information 
with agency officials and noted that data were reported by the agency. 
Based on our review of agency officials' responses to our questions 
and of budget documentation, we determined that the recipient and 
funding data we reported were sufficiently reliable to include in this 
report. 

[End of section] 

Appendix II: Federal Programs that Provide Transition Services to 
Youth with Disabilities: 

Tables 2 to 6 of this appendix contain information on various federal 
programs that provide transition services to youth with disabilities. 

Table 2: Education Programs Providing Transition Services to Youth 
with Disabilities (Ranked by Funding Level): 

Program: Special Education Grants to States; 
Purpose: Provide free appropriate public education to all children 
with disabilities; 
Types of transition services provided: 
* Instruction; 
* Community experiences; 
* Development of employment and other post-school adult living 
objectives; 
* Daily living skills; 
* Functional vocational evaluation; 
* Transportation; 
* Physical and occupational therapy; 
Eligibility criteria: Child with a disability (i.e., intellectual, 
emotional, or learning disabilities; hearing, speech, language, 
visual, or orthopedic impairments; autism; traumatic brain injury; or 
other health impairments) who needs special education and related 
services, as determined by a team of qualified professionals and the 
child's parent; 
Recipient data[A]: Total number of recipients served in school year 
2010-11: 6,558,053; 
Number and percentage of recipients who were transition-age youth[C] 
in school year 2010-11: 2,198,474; (34 percent); 
Funding[B]: Type of funding: Formula grants and program technical 
assistance to states, fiscal year (FY) 2011 obligations: $11.5 billion; 
FY 2012 appropriations: $11.6 billion. 

Program: Vocational Rehabilitation State Grants; 
Purpose: Assist states in creating and operating comprehensive 
rehabilitation programs to prepare disabled individuals for 
competitive employment; 
Types of transition services provided: 
* Job-related services including job search and placement; 
* Vocational guidance and counseling; 
* Vocational or other training services; 
* Assistive and rehabilitation technology; 
* Supported employment; 
* Transportation; 
Eligibility criteria: Individual with a disability (i.e., a physical 
or mental impairment that results in a substantial impediment to 
employment) who requires vocational rehabilitation services to prepare 
for, secure, retain, or regain employment; 
Recipient data[A]: Total number of recipients served in FY 2011: 
589,773[D]; 
Number and percentage of recipients who were transition-age youth[E] 
in FY 2011: 179,535[D]; (30 percent); 
Funding[B]: Type of funding: Formula grants to states; 
FY 2011 obligations: $2.9 billion[I]; 
FY 2012 appropriations: $3.1 billion. 

Program: Centers for Independent Living; 
Purpose: Establish, operate, and provide financial assistance to a 
statewide network of centers for independent living, designed to 
enhance independence and productivity of individuals with significant 
disabilities; 
Types of transition services provided: 
* Information and referral services; 
* Independent living skills training; 
* Peer counseling; 
* Advocacy; 
Eligibility criteria: Individual with a significant disability means 
an individual with a severe physical or mental impairment whose 
ability to function independently in the family or community or whose 
ability to obtain, maintain, or advance in employment is substantially 
limited and for whom the delivery of independent living services will 
improve the ability to function, continue functioning, or move toward 
functioning independently in the family or community or to continue in 
employment, respectively; 
Recipient data[A]: Total number of recipients served in FY 2011: 
238,005; 
Number and percentage of recipients who were transition-age youth[F] 
in FY 2011: 31,703; (13 percent); 
Funding[B]: Type of funding: 
Grants to consumer-controlled, community based, cross-disability, 
nonresidential private nonprofit agencies; 
FY 2011 obligations: $80.1 million; 
FY 2012 appropriations: $80 million. 

Program: American Indian Vocational Rehabilitation Services; 
Purpose: Provide vocational rehabilitation services to American 
Indians with disabilities residing on or near Federal or State 
reservations and help them prepare for and engage in gainful 
employment; 
Types of transition services provided: 
* Job-related services including job search and placement; 
* Vocational guidance and counseling; 
* Vocational or other training services; 
* Assistive and rehabilitation technology; 
* Supported employment; 
* Transportation; 
Eligibility criteria: American Indian (i.e., person who is a member of 
any federal or state Indian tribe or community) with a disability 
(i.e., a physical or mental impairment that results in a substantial 
impediment to employment); 
Recipient data[A]: Total number of recipients served in FY 2011: 
8,130 (approximately); 
Number and percentage of recipients who were transition-age youth[E] 
in FY 2011: Data on age of individuals served not collected; 
Funding[B]: Type of funding: Grants to governing bodies of Indian 
tribes or consortia of those governing bodies located on federal and 
state reservations; 
FY 2011 obligations: $43.6 million; 
FY 2012 appropriations: $37.9 million. 

Program: Supported Employment Services for Individuals with the Most 
Significant Disabilities; 
Purpose: Provide supplemental funds to state vocational rehabilitation 
agencies to help support the cost of supported employment services for 
individuals with the most significant disabilities participating in 
the VR State Grants program; 
Types of transition services provided: 
* On-the-job and systematic training; 
* Job development; 
* Follow-up services; 
* Observation and supervision at training sites; 
Eligibility criteria: Individual eligible for vocational 
rehabilitation services, determined to have a most significant 
disability, and for whom supported employment is the rehabilitation 
objective based on a comprehensive assessment of rehabilitation needs; 
Recipient data[A]: Total number of recipients served in FY 2011: 
34,667[D]; 
Number and percentage of recipients who were transition-age youth[E] 
in FY 2011: 13,454[D]; (39 percent); 
Funding[B]: Type of funding: 
Formula grants to state vocational rehabilitation agencies; 
FY 2011 obligations: $29.1 million; 
FY 2012 appropriations: $29.1 million. 

Program: Special Education--Parent Training and Information Centers; 
Purpose: Ensure parents of children with disabilities receive training 
and information to help improve results for their children; 
Types of transition services provided: 
* Financial support of parent information centers and community parent 
resource centers; 
* Technical assistance; 
Eligibility criteria: Parent of child or youth with a disability 
(i.e., intellectual, emotional, or learning disabilities; hearing, 
speech, language, visual, or orthopedic impairments; autism; traumatic 
brain injury; or other health impairments) or parent who suspects 
their child may have a disability or has been inappropriately 
identified as having a disability; 
Recipient data[A]: Total number of recipients served in FY 2011: 
1,498,007[G]; 
Number and percentage of recipients who were transition-age youth[E] 
in FY 2011: 107,600[G] (parents of transition-age youth); (7 percent); 
Funding[B]: Type of funding: Project grants to parent organizations; 
FY 2011 obligations: $28 million; 
FY 2012 appropriations: $28.9 million. 

Program: Assistive Technology State Grants; 
Purpose: Maximize access to assistive technology devices and assistive 
technology services for individuals with disabilities and their family 
members; 
Types of transition services provided: 
* Assistive technology devices and services; 
Eligibility criteria: Individual with a disability (as defined by any 
federal or applicable state law) who would be enabled by assistive 
technology device or service to minimize deterioration in functioning, 
to maintain a level of functioning, or achieve a greater level of 
functioning in any major life activity; 
Recipient data[A]: Total number of recipients served in FY 2011: 
1,375,472; 
Number and percentage of recipients who were transition-age youth in 
FY 2011: Data on age of individuals served not collected; 
Funding[B]: Type of funding: Formula grants to states; 
FY 2011 obligations: $25.6 million; 
FY 2012 appropriations: $25.6 million. 

Program: Independent Living State Grants; 
Purpose: Expand and improve independent living services to individuals 
with significant disabilities. Services are intended to promote full 
integration and inclusion of individuals into mainstream society; 
Types of transition services provided: 
* Core independent living services, including training; 
* Support independent living centers operations; 
* Outreach to unserved and underserved populations; 
Eligibility criteria: Individual with a significant disability means 
an individual with a severe physical or mental impairment whose 
ability to function independently in the family or community or whose 
ability to obtain, maintain, or advance in employment is substantially 
limited and for whom the delivery of independent living services will 
improve the ability to function, continue functioning, or move toward 
functioning independently in the family or community or to continue in 
employment, respectively; 
Recipient data[A]: Total number of recipients served in FY 2011: 
59,391; 
Number and percentage of recipients who were transition-age youth[F] 
in FY 2011: 4,826; (8 percent); 
Funding[B]: Type of funding: Formula grants to states; 
FY 2011 obligations: $23.4 million; 
FY 2012 appropriations: $23.4 million. 

Program: Protection and Advocacy of Individual Rights; 
Purpose: Support systems for protection and advocacy for the rights of 
individuals with disabilities who are ineligible for advocacy services 
from other programs; 
Types of transition services provided: 
* Information and technical assistance; 
* Advocacy services; 
* Legal representation, including legal counsel and litigation 
services; 
Eligibility criteria: Individual with a disability (i.e., a physical 
or mental impairment that results in a substantial impediment to 
employment) who requires vocational rehabilitation services to prepare 
for, secure, retain, or regain employment and who needs protection and 
advocacy services beyond the scope of other programs; 
Recipient data[A]: Total number of recipients served in FY 2011: 
14,739; 
Number and percentage of recipients who were transition-age youth in 
FY 2011: Data on age of individuals served not collected; 
Funding[B]: Type of Funding: Formula grants to designated protection 
and advocacy agencies; 
FY 2011 obligations: $17.7 million[H,I]; 
FY 2012 appropriations: $17.7 million[H,I]. 

Program: Model Comprehensive Transition and Postsecondary Programs for 
Students with Intellectual Disabilities (TPSID); 
Purpose: Create or expand model comprehensive transition and 
postsecondary programs for students with intellectual disabilities. 
Funds also support a coordinating center that provides related 
services; 
Types of transition services provided: 
* Technical assistance and information; 
* Academic enrichment; 
* Socialization; 
* Independent living skills, including self-advocacy; 
* Integrated work experiences and career skills; 
* Individual planning for course of study; 
Eligibility criteria: Student with an intellectual disability (i.e., 
cognitive impairment with significant limitations in intellectual and 
cognitive functioning and adaptive behavior) who is or was eligible 
for special education and related services; 
Recipient data[A]: Total number of recipients served in FY 2011: 507; 
Number and percentage of recipients who were transition-age youth in 
FY 2011: 430; (85 percent); 
Funding[B]: Type of funding: Grants to institutions of postsecondary 
education; 
FY 2011 obligations: $11 million[I]; 
FY 2012 appropriations: $11 million. 

Program: Helen Keller National Center for Deaf-Blind Youth and Adults; 
Purpose: Maximize employment and independent living opportunities for 
deaf-blind individuals by providing services to those individuals, 
their families, and service providers nationwide; 
Types of transition services provided: 
* Training, counseling, and technical assistance; 
* Service projects; 
* Work experiences and internships; 
* Vocational and rehabilitation services; 
* Short-term training for youth in secondary education; 
Eligibility criteria: Individual who is deaf-blind (i.e., has a low 
central visual acuity with corrective lenses, a visual field defect, 
or a progressive visual loss; has a severe chronic hearing impairment 
or progressive hearing loss; and has extreme difficulty attaining 
independence in daily life activities or employment due to these 
impairments); 
Recipient data[A]: Total number of recipients served in FY 2011: 1,356; 
Number and percentage of recipients who were transition-age youth in 
FY 2011: Data on age of individuals served not collected; 
Funding[B]: Type of Funding: Non-competitive grant to Helen Keller 
Services for the Blind, Inc.; 
FY 2011 obligations: $9.1 million[I]; 
FY 2012 appropriations: $9.1 million. 

Program: Protection and Advocacy for Assistive Technology; 
Purpose: Support protection and advocacy services to assist in the 
acquisition, utilization, or maintenance of assistive technology 
devices and services for individuals with disabilities; 
Types of transition services provided: 
* Information services; 
* Advocacy services; 
* Legal representation; 
Eligibility criteria: Individual with a disability (as defined by any 
federal or applicable state law) who would be enabled by an assistive 
technology device or service to minimize deterioration in functioning 
or achieve a greater level of functioning in any major life activity; 
Recipient data[A]: Total number of recipients served in FY 2011: 2,089; 
Number and percentage of recipients who were transition-age youth in 
FY 2011: Data on age of individuals served not collected; 
Funding[B]: Type of Funding: Formula grants to designated protection 
and advocacy agencies; 
FY 2011 obligations: $4.3 million; 
FY 2012 appropriations: $4.3 million. 

Program: Rehabilitation Services Demonstration and Training Programs 
(Transition Model Demonstration Grants); 
Purpose: Provide financial assistance to projects and demonstrations 
that expand and improve the provision of rehabilitation and related 
services; 
Types of transition services provided: 
* Technical assistance; 
* Supported employment; 
* Parent information and training; 
* Career preparatory and pre-employment experiences; 
* Youth development activities; 
* Practices to enhance family involvement; 
Eligibility criteria: Individual with a disability (i.e., a physical 
or mental impairment that results in a substantial impediment to 
employment) who requires vocational rehabilitation services to prepare 
for, secure, retain, or regain employment; 
Recipient data[A]: Total number of recipients served in FY 2011: 2,096; 
Number and percentage of recipients who were transition-age youth in 
FY 2011: 2,096; (100 percent); 
Funding[B]: Type of funding: Grants to states and public or nonprofit 
organizations; 
FY 2011 obligations: $3 million[I,J]; 
FY 2012 appropriations: $0 (funding for program ended in FY2011). 

Source: Catalog of Federal Domestic Assistance and information 
provided by Department of Education officials. 

[A] Data reported on transition-age youth refer to youth ages 14 to 
25, unless otherwise noted. All recipient data reported by agency 
officials. 

[B] Funding data obtained from publicly available and agency-provided 
budget documentation, unless otherwise noted. 

[C] Includes youth ages 14 to 22 only; program services end when youth 
turn 22. 

[D] Reflects number of recipients whose cases were closed in FY 11. 
Cases may not have been closed for all individuals who received 
services in FY 11, but information on age is only reported at case 
closure. For the Vocational Rehabilitation Grants to States program, 1 
million individuals were served in FY 11. 34 C.F.R. § 361.42 (2011). 

[E] For this program, data reported are for individuals ages 14 to 24. 

[F] Includes youth ages 5 to 24. However, officials reported the 
preponderance of recipients is older than age 14. 

[G] Reflects the number of instances of services provided. Youth, 
parents, and professionals may request information from the centers 
more than once. 

[H] Amount includes funds used to support training and technical 
assistance. 

[I] Data reported by agency officials. 

[J] Officials reported that this amount represents obligations for 
transition model demonstration grants only. 

[End of table] 

Table 3: HHS Programs Providing Transition Services to Youth with 
Disabilities (Ranked by Funding Level): 

Program: Medicaid Infrastructure Grant; 
Purpose: Develop infrastructure, including linkages between Medicaid 
and other employment-related service agencies, supporting competitive 
employment opportunities for individuals with disabilities; 
Types of transition services provided: 
* Removal of systemic barriers to employment and enhancements to state 
Medicaid programs and services; 
* Specific services may include: 
* Personal assistance; 
* Supported employment; 
* Benefits counseling; 
Eligibility criteria: Individual who is eligible for Supplemental 
Security Income program or was previously eligible but is determined 
to have medically improved; 
Recipient data[A]: Total number of recipients served in FY 2011: 
Data not collected at service recipient level; 
Number and percentage of recipients who were transition-age youth in 
FY 2011: Data not collected at service recipient level; 
Funding[B]: Type of funding: Grants to state Medicaid agencies; 
FY 2011 obligations: $70 million[C]; 
FY2012 appropriations: $0 (funding for program ended in FY 2011). 

Program: Developmental Disabilities Protection and Advocacy; 
Purpose: Support protection of legal and human rights of individuals 
with developmental disabilities; 
Types of transition services provided: 
* Complaints investigation; 
* Mediation; 
* Alternative dispute resolution and litigation; 
* Information on transition services and supports, such as benefits 
counseling; 
Eligibility criteria: Individual with a developmental disability 
(i.e., a severe, chronic disability attributable to a mental and/or 
physical impairment, manifested before age 22 and likely to continue 
indefinitely, resulting in substantial functional limitations, and 
reflecting the need for lifelong or extended services); 
Recipient data[A]: Total number of recipients served in FY 2010: 
21,155; 
Number and percentage of recipients who were transition-age youth[E] 
in FY 2010: 13,750; (65 percent); 
Funding[B]: Type of Funding: Formula grants to states; 
FY 2011 obligations: $40.9 million[C]; 
FY 2012 appropriations: $40.9 million. 

Program: Developmental Disabilities Projects of National Significance -
-Youth Information, Training and Resource Centers, National Youth 
Information Centers; 
Purpose: Increase and support the independence, productivity, and 
community integration and inclusion of individuals with developmental 
disabilities. Youth projects provide capacity building in self 
advocacy for postsecondary education, training, and employment; 
Types of transition services provided: 
* Training; 
* Information dissemination; 
* Outreach; 
Eligibility criteria: Youth with a developmental disability (i.e., a 
severe, chronic disability attributable to a mental and/or physical 
impairment, manifested before age 22 and likely to continue 
indefinitely, resulting in substantial functional limitations, and 
reflecting the need for lifelong or extended services); 
Recipient data[A]: Total number of recipients served in FY 2011: 
11,831; 
Number and percentage of recipients who were transition-age youth in 
FY 2011: Data on age of individuals served not collected; 
Funding[B]: Type of funding: Grants to state and local agencies and 
nonprofit organizations; 
FY 2011 obligations: $100,000[C]; 
FY 2012 appropriations: $0. 

Program: Section 1915(c) and (i) Home and Community Based Services; 
Purpose: Allow states to provide long term care services in home and 
community based settings, as an alternative to institutional care, 
under the Medicaid program; 
Types of transition services provided: 
* Case management; 
* Independent living assistance; 
* Family training; 
* Supported employment; 
* Environmental modifications; 
* Other services as approved; 
Eligibility criteria: Individual that meets targeting criteria for a 
waiver (e.g., age and condition; 
a state may have a number of waivers targeting different groups) and 
needs-based criteria (e.g., institutional level of care or other level 
determined by the state); 
Recipient data[A]: Total number of recipients served in 2010: 
274,657[D,F]; 
Number and percentage of recipients who were transition-age youth in 
2010: Data on age of individuals served not collected; 
Funding[B]: Type of funding: Matching state-federal partnership; 
FY 2011 federal net expenditures: $37.1 billion[D]; 
FY 2012 appropriations: Data not available. 

Source: Catalog of Federal Domestic Assistance and information 
provided by Department of Health and Human Services officials. 

[A] Data reported on transition-age youth refers to youth ages 14 to 
25, unless otherwise noted. All recipient data reported by agency 
officials. 

[B] Funding data obtained from publicly available and agency-provided 
budget documentation, unless otherwise noted. 

[C] Data reported by agency officials. FY 11 obligations for the 
Medicaid Infrastructure Grant include $23.5 million in carryover 
funding from previous years. 

[D] Most recent data available are from FY 10 because state reporting 
of recipient data to HHS's Centers for Medicare & Medicaid Services 
lags 18 months behind service provision. 

[E] Includes youth ages 5 to 25. Data are not collected for the 14 to 
25 age group. 

[F] Agency officials did not specify whether these data were for the 
FY. 

[End of table] 

Table 4: Department of Justice Program Providing Transition Services 
to Youth with Disabilities: 

Program: Juvenile Mentoring Program --Mentoring for Youth with 
Disabilities Initiative; 
Purpose: Provide mentoring services to youth with disabilities who are 
in the juvenile justice system or at risk of delinquency to ensure 
they develop into healthy, productive adults; 
Types of transition services provided: 
* Mentoring; 
Eligibility criteria: Youth under age 18 with a disability as defined 
by the Americans with Disabilities Act (i.e., a physical or mental 
impairment that substantially limits the performance of one or more 
major life activities); 
Recipient data[A]: Total number of recipients served in FY 2011: Data 
not yet available; 
Number and percentage of recipients who were transition-age youth in 
FY 2011: Data not yet available; 
Funding[B]: Type of funding: Grants to states, public and nonprofit 
organizations, and postsecondary institutions; 
FY 2011 obligations: $2.2 million; 
FY 2012 appropriations: $78 million appropriated for youth mentoring; 
no separate allocation for this program. 

Source: Catalog of Federal Domestic Assistance and information 
provided by Department of Justice Officials: 

[A] Data reported on transition-age youth refer to youth ages 14 to 
25, unless otherwise noted. All recipient data reported by agency 
officials. 

[B] Funding data obtained from publicly available and agency-provided 
budget documentation, unless otherwise noted. 

[End of table] 

Table 5: Labor Program Providing Transition Services to Youth with 
Disabilities: 

Program: Disability Employment Initiative; 
Purpose: Improve educational, training, and employment opportunities 
and outcomes for youth and adults with disabilities who are 
unemployed, underemployed, and or receiving Social Security disability 
benefits; 
Types of transition services provided: 
* School-based preparatory experiences; 
* Career preparation and work-based learning experiences; 
* Youth development and leadership; 
* Family involvement and supports; 
* Connecting activities; 
Eligibility criteria: Individuals with disabilities who are eligible 
for employment and training services under the Workforce Investment 
Act, Social Security disability beneficiaries, and in the target 
population of focus as determined by the grantee. Projects with a 
focus on youth target youth ages 14 to 24 (currently, projects in 4 
states serve this specific population); 
Recipient data[A]: Total number of recipients served in FY 2011: Data 
not yet available; 
Number and Percentage of Recipients that were transition-age youth in 
FY 2011: Data not yet available; 
Funding[B]: Type of Funding: Grants to states; 
FY 2011 obligations: $24 million[C]; 
FY 2012 appropriations: $24 million[C]. 

Source: Catalog of Federal Domestic Assistance and information 
provided by Department of Labor officials. 

[A] Data reported on transition-age youth refer to youth ages 14 to 
25, unless otherwise noted. All recipient data reported by agency 
officials. 

[B] Funding data obtained from publicly available and agency-provided 
budget documentation, unless otherwise noted. 

[C] Data reported by agency officials. 

[End of table] 

Table 6: SSA Programs Providing Transition Services to Youth with 
Disabilities (Ranked by Funding Level): 

Program: Ticket to Work; 
Purpose: Provide additional choices for employment services for 
individuals receiving Social Security disability benefits; 
Types of transition services provided: 
* Vocational rehabilitation services; 
* Career counseling and job placement; 
* Ongoing employment support; 
Eligibility criteria: Individuals ages 18 to 65 receiving Social 
Security disability benefits; 
Recipient data[A]: Total number of recipients served in 2011: 
7,812[C,K]; 
Number and percentage of recipients who were transition-age youth in 
2011: 441[C] (6 percent); 
Funding[B]: Type of funding: Contract and blanket funding agreements; 
FY 2011 obligations: $25.7 million[D,E]; 
FY 2012 appropriations: $39 million[F,E]. 

Program: Youth Transition Demonstration; 
Purpose: Assist youth with disabilities to successfully transition 
from school to economic self-sufficiency; 
Types of transition services provided: 
* Individualized work-based experiences; 
* Job development; 
* Youth empowerment and family supports; 
* Social and health services; 
* Benefits counseling; 
* SSA program waivers[G]; 
Eligibility criteria: Youth ages 14 to 25 receiving or likely to 
receive Social Security disability benefits; 
Recipient data[A]: Total number of recipients served from 2007 to 
2012[H,K]: 4,920; 
Number and percentage of recipients who were transition-age youth from 
2007 to 2012[H]: 2,520[I] (51 percent); 
Funding[B]: Type of funding: Demonstration grants to states and 
community organizations; 
FY 2011 obligations: $1.6 million[J]; 
FY 2012 appropriations: $1.5 million[J]. 

Source: Catalog of Federal Domestic Assistance and information 
provided by Social Security Administration officials: 

[A] Data reported on transition-age youth refer to youth ages 14 to 
25, unless otherwise noted. All recipient data reported by agency 
officials. 

[B] Funding data obtained from publicly available and agency-provided 
budget documentation, unless otherwise noted. 

[C] Reflects number of recipients for which SSA paid employment 
networks due to beneficiaries meeting program criteria for work and 
earnings. 

[D] Reflects amounts SSA paid employment networks. 

[E] Data reported by agency officials. 

[F] Reflects amount available for payment to employment networks. 

[G] The Youth Transition Demonstration (YTD) program removes some 
disability program rules to encourage and reward work. For example, 
YTD participants may take advantage of earned-income exclusions, which 
allows SSA to exclude a certain amount of a beneficiary's earned 
income when determining benefits payments. According to SSA officials, 
this is a rigorous research project with a random assignment design 
that will yield real results for this population and help to answer 
questions about better outcomes. They noted that this is the only 
research of its kind on this population: 

[H] Data are reported for the life of the program (2007 through 2012) 
because it is a demonstration program. 

[I] Under the demonstration program, a portion of the participants 
received services while the remaining participants were placed in a 
control group. 

[J] Amounts include project funds from Section 1110 (90 percent of 
funds) and direct apportionments of Section 234 funds (10 percent of 
funds) authorized under the Social Security Act for research and 
demonstration projects, which are not part of the annual research 
appropriations request. Section 234 amounts were reported by agency 
officials. 

[K] Agency officials did not specify whether these data were for the 
FY. 

[End of table] 

Appendix III: Other Federal Coordination Efforts that Address 
Individuals with Disabilities, Including Students: 

Some of the coordination efforts of the Departments of Education 
(Education), Health and Human Services (HHS), Labor (Labor), and the 
Social Security Administration (SSA) broadly address youth or 
individuals with disabilities (see figure 4). A focus on transition-
age students with disabilities may or may not be explicitly included 
in these federal coordination efforts, but agency officials indicated 
that all of these efforts include discussions of programs or policy 
that impact this population in some manner. 

Figure 4: Federal Coordination Efforts That Focus on Individuals with 
Disabilities or Youth: 

[Refer to PDF for image: illustrated table] 

Name and purpose of effort: Interagency Committee on Disability 
Research, Subcommittee on Education[A]: Identify research gaps and 
improve information sharing among partners to encourage coordination 
on disability and rehabilitation research across the federal 
government; 
Education: Agency leads effort; 
HHS: Agency is involved in the effort; 
Key activities coordinated: Guidance to grantees, information exchange 
through databases and websites; 
Mechanisms of coordination: Interagency meetings, regular information 
sharing, interagency or shared databases. 

Name and purpose of effort: Interagency Working Group on Youth 
Programs, Subgroup on Positive Youth Development[B]: Identify 
promising aproaches, strategies, and evidence related to the positive 
development of youth. Full working group responsibilities include 
promoting enhanced collaboration at the federal, state, and local 
levels and developing an overarching strategic plan for federal youth 
policy; 
HHS: Agency leads effort; 
Labor: Agency is involved in the effort; 
Key activities coordinated: Policymaking, standards and practices, 
program planning, information exchange through databases and websites; 
Mechanisms of coordination: Interagency agreements, memoranda of 
understanding, common policies, interagency meetings, joint strategic 
planning, shared performance measurement and reporting, regular 
information sharing, interagency or shared databases, cross-training 
of staff, joint evaluations and reports. 

Name and purpose of effort: President's Committee for People with 
Intellectual Disabilities: Provide advice and assistance to the 
President and the Secretary of HHS in the field of intellectual 
disabilities and improve the quality of life for people with 
intellectual disabilities; 
Education: Agency is involved in the effort
HHS: Agency leads effort; 
Labor: Agency is involved in the effort; 
SSA: Agency is involved in the effort; 
Key activities coordinated: Policymaking, standards and practices, 
performance goals and measures; 
Mechanisms of coordination: Interagency meetings, regular information 
sharing, joint evaluations and reports. 

Name and purpose of effort: United We Ride/Federal Coordinating 
Council on Access and Mobility[C]: Develop a coordinated approach to 
leverage public transportation services to disadvantaged persons 
including those who are elderly, goals and measures, guidance to 
grantees and beneficiaries, low-income, and those with disabilities; 
Education: Agency is involved in the effort
HHS: Agency is involved in the effort; 
Labor: Agency is involved in the effort;
Key activities coordinated: Policymaking, performance goals and 
measures, guidance to grantees and beneficiaries, program planning; 
Mechanisms of coordination: Memoranda of understanding, common 
policies, interagency meetings, regular information sharing, joint 
training of grantees, information sessions for beneficiaries. 

Source: GAO analysis of information provided by agency officials.  

Note: While some coordination efforts included in this figure involve 
other federal agencies, we focused on Education, HHS, Labor, and SSA 
because they administer the key programs that serve students in their 
transition out of high school. Key activities coordinated and 
mechanisms of coordination were reported by at least half of the 
reporting member agencies. For efforts with two key member agencies, 
only mechanisms and activities reported by both agencies were included. 

[A] Participating offices from HHS include the National Institutes of 
Health, Indian Health Service, and Centers for Disease Control and 
Prevention. The Administration on Developmental Disabilities (ADD) at 
HHS is planning to re-engage in this effort. Key activities 
coordinated and mechanisms of coordination were reported by Education. 

[B] The Office of the Assistant Secretary for Planning and Evaluation 
at HHS leads this effort. Key activities coordinated and mechanisms of 
coordination were reported by Labor. 

[C] The Department of Transportation leads this council. ADD at HHS is 
planning to re-engage in this effort. Key activities coordinated and 
mechanisms of coordination were reported by Labor. 

[End of figure] 

Appendix IV: Comments from the Department of Education: 

United States Department of Education: 
Office of Special Education and Rehabilitative Services: 
The Assistant Secretary: 
400 Maryland Ave, SW: 
Washington, DC 20202-2500: 

June 15, 2012: 

Ms. Revae Moran: 
Director: 
Education, Workforce, and Income Security Issues: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Ms. Moran: 

I am writing to provide the U.S. Government Accountability Office 
(GAO) with comments from the U.S. Department of Education (Department) 
on the draft report, "Students With Disabilities -- Better Federal 
Coordination Could Lessen Challenges in the Transition from High 
School" (GA0-12-594). The Department appreciates the work that went 
into this study. The draft report contains the following 
recommendation for executive action to the Secretaries of the 
Departments of Education, Health and Human Services (HHS), Labor 
(DOL), and the Commissioner of the Social Security Administration 
(SSA), with three subparts and a suggestion for identifying potential 
legislative changes that might be needed. 

Recommendation for Executive Action: 

To improve the provision of transition services to students with 
disabilities through enhanced coordination among the multiple federal 
programs that support this population, we recommend that the 
Secretaries of Education, HHS, Labor, and the Commissioner of SSA 
direct the appropriate program offices to work collaboratively to 
develop a federal interagency transition strategy. This strategy 
should address: 

1. compatible policies, procedures, and other means to operate across 
agency boundaries towards common outcomes for transitioning youth and 
their families; 

2. methods to increase awareness among students, families, high school 
teachers, and other service providers on the range of available 
services; and; 

3. ways to assess the effectiveness of federal coordination efforts in 
providing transition services. 

To the extent that legislative changes are needed to facilitate the 
implementation of this transition strategy, agencies should identify 
and communicate them to the Congress. 

Department of Education Response: 

The Department of Education is currently engaged in numerous 
transition coordinating activities with HHS, DOL, and SSA related to 
discretionary grants, legislative proposals, draft regulations. policy 
positions, and program improvements. While the draft report provides 
some helpful examples of coordination, such as the Promoting Readiness 
of Minors in Supplemental Security Income (PROMISE) grants planning, 
it does not fully discuss the coordinated efforts that are taking 
place. We continue to work closely with our agency partners. For 
example, just this past May 2012, we hosted the National Transition 
Conference. Together, the Department of Education, HHS, DOL, and SSA 
planned, collaborated, and participated in all stages of the 
conference process with the goals of raising awareness of services, 
sharing promising practices, and creating an action agenda to improve 
transition outcomes for youth with disabilities. 

However, we acknowledge that further work is necessary. We concur with 
GAO's recommendation that the development of a more formal federal 
interagency transition strategy would be useful for all four agencies, 
and an effective strategy could include programs from other agencies 
as well. We have been in contact with HHS, DOL, and SSA regarding the 
recommendations and will quickly hold preliminary discussions about 
how to best implement these recommendations. 

Thank you for the opportunity to comment on this draft report. We have 
also forwarded technical comments and suggestions. 

Sincerely, 

Signed by: 

Alexa Posny, Ph.D. 

[End of section] 

Appendix V: Comments from the Department of Health and Human Services: 

Department of Health & Human Services: 
Office of The Secretary: 
Assistant Secretary for Legislation: 
Washington, DC 20201: 

June 21, 2012: 

Revae Moran, Director: 
Education, Workforce, and Income Security Issues: 
U.S. Government Accountability Office: 
441 G Street NW: 
Washington, DC 20548: 

Dear Ms. Moran: 

Attached are comments on the U.S. Government Accountability Office's 
(GAO) report entitled: "Students With Disabilities: Better Federal 
Coordination Could Lessen Challenges in the Transition from High 
School" (GAO-12-594). 

The Department appreciates the opportunity to review this draft 
section of the report prior to publication. 

Sincerely, 

Signed by: 

Jim R. Esquea: 
Assistant Secretary for Legislation: 

Attachment: 

The Department appreciates the opportunity to comment on this draft 
report. 

The purpose of the report was to provide information on 1) the 
challenges students with disabilities may face accessing federally 
funded transition services; and 2) the extent to which federal 
agencies coordinate their transition services. GAO reviewed relevant 
federal laws, regulations, and agency documents from the Social 
Security Administration (SSA) and the Departments of Education, Health 
and Human Services, and Labor, which administer the key transition 
programs. GAO also administered a data collection instrument to gather 
program information from these agencies. Finally, GAO interviewed 
various stakeholder% including state and local officials, service 
providers, parent% and a targeted group of students with disabilities. 

GAO Findings: 

GAO found that the current federal approach to assisting students with 
disabilities in their transition to postsecondary education or the 
workforce requires the students and their parents to navigate multiple 
programs and service systems to piece together the supports the 
students need to achieve maximum independence in adulthood. Under this 
complex structure, information dissemination and service coordination 
are essential. Without receiving accurate and timely information about 
available services, students may miss opportunities to access needed 
services that could mean the difference between achieving an optimal 
level of self-sufficiency and relying on public assistance to meet 
basic needs. While officials report that federal agency coordination 
efforts, such as the Federal Partners in Transition Workgroup, have 
improved relationships and knowledge sharing across participating 
agencies, they have yet to adopt a broader interagency strategy to 
addressing longstanding challenges in providing transition services to 
students with disabilities. The Transition Workgroup, in particular, 
represents a unique vehicle that could provide leadership in 
developing such a strategy specifically focused on students with 
disabilities who are transitioning out of high school. 

Given the multiple agencies involved in supporting this population, in 
conjunction with multiple eligibility criteria and definitions 
established in statute, the lack of such a strategy is a missed 
opportunity to break down coordination barriers and improve work 
across agency boundaries. Only through a strategic approach can 
agencies systemically address persistent transition challenges and 
improve outcomes for students with disabilities. Furthermore, without 
an assessment of the effectiveness of federal coordination effort% 
agencies are unable to determine what works well what needs 
improvement, and where best to direct increasingly constrained federal 
resources. 

GAO Recommendation: 

To improve the provision of transition services to students with 
disabilities through enhanced coordination among the multiple federal 
programs supporting this population, GAO recommends that the 
Secretaries of Education, HHS, Labor, and the Commissioner of SSA 
direct the appropriate program offices to work collaboratively to 
develop a federal interagency transition strategy. This strategy 
should address: 

1. Compatible policies, procedures, and other means to operate across 
agency boundaries toward common outcomes for transition youth and 
their families; 

2. Methods to increase awareness among students, families, high school 
teachers, and other service providers on the range of available 
transition services; and; 

3. Ways to assess the effectiveness of federal coordination efforts in 
providing transition services. 

To the extent that legislative changes are needed to facilitate the 
implementation of the transition strategy, agencies should identify 
and communicate them to Congress. 

HHS Response: 

We agree with GAO's recommendation. We believe that it is important 
that reasonable, realistic transition plans are included in all 
individuals with disabilities' educational plans, and that this goal 
will more likely be realized through enhanced collaboration among 
federal partners, a more concerted effort to increase awareness of 
transition programs, and an evaluation of this work in order to better 
understand the strengths and weaknesses. 

The purpose of the Developmental Disabilities Assistance and Bill of 
Rights Act of 2000 (DD Act) is to assure "self-determination, 
independence, productivity, and integration and inclusion in all 
facets of community life for individuals with developmental 
disabilities and their families. Current challenges are considerable; 
the graduation rate for people with people with intellectual and 
developmental disabilities (ID/DD) hovers around 35 percent,[Footnote 
1] less than a quarter of people with ID/DD work in competitive, 
integrated employment and people with ID/DID experience 
disproportionately high poverty rates. Among all students, those with 
the most significant cognitive disabilities are the least likely to 
graduate with a regular high school diploma.[Footnote 2] As the
report articulates, students who receive an alternative diploma may 
face additional challenges. 

Even with a diploma, youth with intellectual disabilities demonstrate 
the lowest rate of paid employment among students with disabilities 
(29.8 percent), one to four years after exiting high school.[Footnote 
3] Given the larger context of low overall rates of employment for 
people with disabilities,[Footnote 4] it is crucially important to 
support successful transition outcomes for youth, toward pursuing life-
long learning and careers. High expectations for all youth, including 
individuals with developmental disabilities, must be established early 
and maintained. 

HHS strongly agrees with the need for greater coordination and the 
development of a transition strategy, and underscores that success in 
shaping the transition from high school for students with disabilities 
requires a comprehensive and holistic approach, which must include 
flexible supports, healthcare, transportation and housing 
considerations, among other issues. With the understanding that this 
report focuses on the highest-profile, targeted efforts currently 
underway within the federal government successful transition planning 
requires broad coordination, and GAO might consider future involvement 
of additional players, including, for example, the Department of 
Housing and Urban Development among other important partners. As 
flagged in opening letter on page one academic as well as "other 
supports" are necessary to enable students with disabilities to 
achieve their goals. 

HHS underscores the report's suggestions regarding the need for 
increased coordination between programs; the utility of eliminating 
administrative burden on students and families to provide similar 
information to multiple programs and problematic gaps or delays in 
service; the importance of identifying transportation challenges and 
the provision of necessary services post-high school, such as personal 
care attendants. Useful, additional suggestions from the report
include creating a transition manual and additional training for all 
professionals who work with students in transition, both of which 
require/benefit from additional coordination between agencies. 

The report identifies a key obstacle that federal agencies must 
address to create successful transition outcomes: the requirement for 
students to prove that their disability limits their ability to work 
in order to receive SSI benefit& with the corresponding impact on 
needed health benefits. These current SSI eligibility requirements 
serve as a disincentive for youth with
disabilities to pursue competitive employment. Successful transition 
planning efforts must also include medical/healthcare transition 
issue& such as moving from pediatric care to adult care,
and benefits management and coordination. Additional elements should 
include information on accessing reasonable accommodations in the 
workplace. 

Information dissemination and service coordination within federal 
agencies, with state and local partners as well as for the public, 
generally, are essential to improve outcomes for students with 
intellectual and developmental disabilities. The Federal Partners in 
Transition Workgroup currently provides one.means for sharing 
information. However, increased collaboration and communication are 
needed. Though some positive initial efforts have begun, including the
recent 2012 National Transition Conference, which included input from 
several of the agencies included in the GAO report, more must be done 
toward developing a coordinated, integrated transition strategy. 

Additional recommendations for GAO's consideration include the need to 
emphasize person-centered planning and self-determination in 
transition planning efforts. GAO may also want to consider the role of 
and need for coordination with states for transition planning and 
preparation efforts. For example, state ID/DD agencies play a critical 
role in determining the direction of the state and federal Medicaid 
investment. Transition planning efforts should also include 
coordination of community based non-work activities supported by home 
and community-based waivers and state funds. Finally, transition 
planning by federal entities should also include other work-based 
experiences, such as volunteering, mentoring and community service. 

Programs Included in the Report: 

MIS, through its Administration on Intellectual and Developmental 
Disabilities (AIDD), works with our partners to achieve the goals 
embodied in the DD Act funding capacity-building and systems change 
efforts to assure that people with intellectual and developmental 
disabilities and their families participate in the design of and have 
access to needed community services, individualized supports, and 
other forms of assistance that promote self-determination, 
independence, productivity, and integration and inclusion in all 
facets of community life. The AIDD network consists of three programs 
that operate in each state and territory: State Developmental 
Disabilities Councils (SCDDs), University Centers for Excellence in
Developmental Disabilities (UCEDDs), and the Developmental 
Disabilities Protection and Advocacy (PADD) system. AIDD also 
implements the Projects of National Significance (PNS), which are 
designed to support the network through data and research projects as 
well as fund innovative approaches to improving outcomes for those 
with developmental disabilities. 

We note that the organizations contacted in preparation of the report 
included the State DD Council in California, though not in the other 
states, and not the other DD Network entities in the select states 
(UCEDDs and the PADD). We hope that efforts were taken in interviews 
with parents of and students with disabilities to include the 
perspectives of people with ID/DD and their families. 

Figure 1 is somewhat deceptive in stating that the DD Act provides 
employment and training services, Priorities for DD Network programs 
are set at state and local discretion. Those goals and priorities are 
again, determined at the state or territory level, rather than 
coordinated at the federal level, and no federal AIDD funds are 
currently allocated to provide employment and training services 
directly. The DD Act largely supports systems-change activities, 
rather than direct services. Many AIDD network entities report active 
engagement related to improving employment outcomes for people with 
developmental disabilities, through a broad range of activities 
including development of state and local policies and practices, 
protection of employment right& data collection and analysis and 
training initiatives. Typically, transition services are not provided 
directly. 

To evaluate federal programs that provide transition services to youth 
with disabilities, the report identifies a list of selected programs 
that includes the criteria that they "Provide transition services 
directly to youth going from high school to post secondary education 
or the workforce and their families." With this parameter in mind, the 
information included in the report with respect to AIDD's programs 
(Table 3 includes PADD, though it is, listed as 'Protection and
Advocacy of Individual Rights," which is the name of a similar program 
administered by the Department of Education, and certain PNS programs) 
may not reflect what the report intends to capture. 

The Developmental Disabilities Protection and Advocacy program (PADD) 
provides formula grants to establish and maintain a Protection and 
Advocacy (P&A) system in each state, to protect the legal and human 
rights of all persons with developmental disabilities: The P&A system 
has the authority to pursue legal, administrative, and other 
appropriate remedies or approaches, including the authority to 
investigate incidents of abuse and neglect and to access client 
records. It is inaccurate to categorize the full PADD budget as 
supporting transition-based services and to count the number of people 
served and apply it in this context. PADD services; to protect the 
legal and human rights of individuals with developmental disabilities, 
cover a range of priorities, including education and early 
intervention activities, child care, health-related activities, 
employment, housing, transportation, recreation, and other services 
available or offered to individuals in a community, including formal 
and informal community supports that affect quality of life. It is 
overly inclusive and inaccurate to list the whole of the P&A funding 
in a table on transition activities. With respect to tracking 
recipient data AIN? does not currently collect data based on 
transition services nor on the target population identified here, as 
noted in footnote e. This is also true of the UCEDD and SCDD programs. 
Although an individual UCEDD or SCDD may determine in its priority-
setting and planning process that it will address transition issues, 
it would be equally inaccurate to state that the whole of the UCEDD 
and SCDD program budgets support transition efforts. 

PNS resources grants improve access to competitive, integrated 
supported employment for people with intellectual and developmental 
disabilities with a particular focus on youth and young adult& as well 
as the evaluation of such efforts. 

Table 3 includes an entry for Partnership in Employment Systems Change 
Grants. Six Partnerships in Employment Systems Change projects have 
been awarded under AIDD's PNS program. These grantees have partnered 
with various state agencies to form a consortium to develop and 
implement initiatives designed to improve the employment outcomes of 
individuals with intellectual and developmental disabilities to 
participate in competitive employment in integrated settings and 
improve statewide system policies and practices. The grantees document 
their systems change efforts throughout the project period. Please 
note that these projects are not intended or designed to provide 
direct services. These grants focus on the goal of improving 
employment outcomes, but do not fund transition services, per se. 
There are similar problems with respect to the Youth Information, 
Training and Resource Centers PNS entry included in the chart, as the 
information provided may be misleading. The project provided training 
to youth and emerging leaders on various topics including transition. 
It did not however, provide direct funding for transition services. 

Again, AIDD does not track whether these recipients are transition 
aged youth. To do so would necessitate a new resource-intensive 
reporting effort. 

In addition to the information included in the report AIDD provides 
funds for the Consortium to Enhance Postsecondary Education for 
Individuals with Developmental Disabilities, a National Training 
Initiative through Think College! that conducts research, provides 
training and technical assistance, and disseminates information on 
promising practices that support individuals with developmental 
disabilities to increase their independence, productivity and 
inclusion through access to postsecondary education resulting in 
improved long-term independent living and employment outcomes. The 
Consortium is a national resource for knowledge, training, materials, 
and dissemination about the participation of individuals with 
developmental disabilities in postsecondary education. 

Also since 2010, AIDD, the Administration on Children and Families, 
the Department of Health and Human Service% the Department of Labor 
and the Department of Education have been involved in Project SEARCH, 
a program to support local students with disabilities in their last 
year of high school to experience work opportunities within these 
federal agencies. Additionally, these federal agencies have worked 
collaboratively to conduct a Program Evaluation of the Federal Project 
SEARCH Model. 

We hope this additional information provides clarity regarding the 
programs and transition efforts overseen by HHS/AIDD. We look forward 
to a continued dialogue on how to improve transition services for all 
students. 

Footnotes: 

1. See, e.g., U.S. Department of Education, (2010). Individuals with 
Disabilities Education Act Data — Data Accountability Center, Exiting 
Children and students served under IDEA, Part B, in the U.S. and 
outlying areas by age group, year and disability category, 2008. Table 
4-2. 

2. Wagner, M., Newman, L., Cameto, R, Levine, P, and Garza, N. (2006). 
An overview of findings from Wave 2 of the National Longitudinal 
Transition Study-2 (NLTS2). Menlo Park, CA: SRI International. 

3. Newman, L., Wagner, M., Cameo, R., Knokey, A.M., & Shaver, D. 
(2010). Comparisons Across Time of the Outcomes of Youth With 
Disabilities up to 4 Years After High. School. A Report of Findings 
from the National Longitudinal Transition Study-2 (NL7S2). Page 37. 
Menlo Park, CA: SRI International, available at [hyperlink, 
http://www.nits2.org/reports/2010_09/nIts2_report_2010_09_complete_pdf].
 
4. See, e.g., Current Disability Employment Statistics reported by the 
Department of Labor, available at [hyperlink, 
http://www.dol.goviodep/]. 

[End of section] 

Appendix VI: Comments from the Department of Labor: 

U.S. Department of Labor: 
Assistant Secretary for Office of Disability Employment Policy: 
200 Constitution Avenue, NW: 
Washington, DC 20210: 

June 13, 2012: 

Ms. Revae Moran: 
Director, Education, Workforce and Income Security Issues: 
U.S. Government Accountability Office: 
441 G Street, NW Washington, DC 20548: 

Dear Ms. Moran: 

On behalf of the U.S. Department of Labor (Department), I want to 
thank you for the opportunity to review and comment on the Government 
Accountability Office's (GAO) draft report, "Students with 
Disabilities - Better Federal Coordination Could Lessen Challenges in 
the Transition from High School" (GAO-12-594). 

The Department of Labor (Department) agrees with the report's 
recommendation to the Secretaries of Education, Health and Human 
Services, Labor, and the Commissioner of the Social Security 
Administration to direct the appropriate program offices to work 
collaboratively to develop a federal interagency transition strategy. 
We will consider the various strategies articulated in the report. 

At the Department, we recognize that all students, and in particular 
students with disabilities, face challenges when navigating from 
secondary education into the adult world. The Department is committed 
to continuing to work collaboratively with our federal partners at the 
Departments of Education (ED), Health and Human Services (HHS), and 
the Social Security Administration (SSA). The existing synergy between 
these agency partners to improve outcomes for youth with disabilities 
was evidenced just last week at the National Transition Conference 
held in Washington DC. Together, the Department, ED, HHS, and SSA 
planned the conference with the goals of raising awareness of 
services, sharing promising practices, and creating an action agenda 
to improve transition outcomes for youth with disabilities. 

The Department agrees that a more formalized federal interagency 
transition strategy would be useful in helping to systemically address 
persistent challenges, break down barriers, and improve post-school 
outcomes for students with disabilities. Accordingly, consistent with 
your recommendation, we will be reaching out to the Departments of 
Education and the Social Security Administration to explore ways to 
formalize the Federal Partners in Transition Workgroup, led by the 
Department's Office of Disability Employment Policy, as a possible 
vehicle. This federal interagency group would help to align policies, 
services and supports provided by the various programs that provide 
services to transition-aged youth, and to increase awareness about the 
range of transition services available among students, families, and 
high school teachers and other service providers. In addition, it 
would work collaboratively to identify and address, legislative and 
regulatory barriers that prevent effective and coordinated transition 
service delivery, and would assess the impact of its coordination 
efforts through the use of common outcome goals. To measure its 
success, the group will consider using the Guideposts for Success (see 
[hyperlink, http://www.ncwd-youth.info/guideposts]), an evidenced-based
framework developed and validated by ODEP in collaboration with the 
involved partner agencies. 

Again, thank you for the opportunity to review and comment on the 
draft report. If you would like additional information, please do not 
hesitate to call me at 202-693-7880. 

Sincerely, 

Signed by: 

Kathy Martinez: 

[End of section] 

Appendix VII: Comments from the Social Security Administration: 

Social Security: 
Office of the Commissioner: 
Social Security Administration: 
Baltimore, MD 21235-0001: 

June 19, 2012: 

Ms. Revae Moran, Director: 
Education, Workforce, and Income Security Issues: 
United States Government Accountability Office: 
441 G. Street, NW: 
Washington, D.C. 20548: 

Dear Ms. Moran: 

Thank you for the opportunity to review the draft report, "Students 
With Disabilities: Better Federal Coordination Could Lessen Challenges 
in the Transition from High School" (GAO-12-594). Our response is 
enclosed. 

If you have any questions, please contact me at (410) 965-0520. Your 
staff may contact Amy Thompson, Senior Advisor for Records Management 
and Audit Liaison Staff, at (410) 966-0569. 

Sincerely, 

Signed by: 

Dean S. Landis: 
Deputy Chief of Staff: 

Enclosure: 

Comments On The Government Accountability Office Draft: 

Could Lessen Challenges In The Transition From High School (GAO-12-
594): 

Recommendation: 

Recommend that the Secretaries of Education, HHS, Labor, and the 
Commissioner of SSA direct the appropriate program offices to work 
collaboratively to develop a federal interagency transition strategy. 
This strategy should address: 1) compatible policies, procedures, and 
other means to operate across agency boundaries towards common 
outcomes for transitioning youth and their families; 2) methods to 
increase awareness among students, families, high school teachers, and 
other service providers on the range of available transition services; 
and 3) ways to assess the effectiveness of federal coordination 
efforts in providing transition services. To the extent that 
legislative changes are needed to facilitate the implementation of 
this transition strategy, agencies should identify and communicate 
them to the Congress. 

Response: 

We agree. We currently coordinate with the Departments of health and 
Human Services (HHS), Labor (DOL), and Education on a number of 
activities related to the transition of youth with disabilities, but 
we agree we should explore more coordination and collaboration on 
common goals and common outcome measures. We are in contact with HITS, 
DOL and Education regarding the recommendation, and we will expedite 
preliminary discussions with these departments on an implementation 
strategy. 

[End of section] 

Appendix VIII: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Revae E. Moran, (202) 512-7215 or moranr@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Meeta Engle (Assistant 
Director), Nora Boretti (Analyst-in-Charge), Rachel Batkins, Brenna 
Guarneros, and Jennifer McDonald made significant contributions to 
this report. In addition, assistance, expertise, and guidance were 
provided by Susan Anthony, James Bennett, Amy Buck, Susannah Compton, 
Elizabeth Curda, Jill Lacey, Kathy Leslie, Craig Winslow, and Carolyn 
Yocom. 

[End of section] 

Related GAO Products: 

High Risk Series: An Update. [hyperlink, 
http://www.gao.gov/products/GAO-11-278]. Washington, D.C.: February 
2011. 

Postsecondary Education: Many States Collect Graduates' Employment 
Information, but Clearer Guidance on Student Privacy Requirements Is 
Needed. [hyperlink, http://www.gao.gov/products/GAO-10-927]. 
Washington, D.C.: September 27, 2010. 

Higher Education and Disability: Education Needs a Coordinated 
Approach to Improve Its Assistance to Schools in Supporting Students. 
[hyperlink, http://www.gao.gov/products/GAO-10-33]. Washington, D.C.: 
October 28, 2009. 

Young Adults with Serious Mental Illness: Some States and Federal 
Agencies Are Taking Steps to Address Their Transition Challenges. 
[hyperlink, http://www.gao.gov/products/GAO-08-678]. Washington, D.C.: 
June 23, 2008. 

Federal Disability Programs: More Strategic Coordination Could Help 
Overcome Challenges to Needed Transformation. [hyperlink, 
http://www.gao.gov/products/GAO-08-635]. Washington, D.C.: May 20, 
2008. 

Highlights of a Forum: Modernizing Federal Disability Policy. 
[hyperlink, http://www.gao.gov/products/GAO-07-934SP]. Washington, 
D.C.: August 2007. 

Summary of a GAO Conference: Helping California Youths with 
Disabilities Transition to Work or Postsecondary Education, 
[hyperlink, http://www.gao.gov/products/GAO-06-759SP]. Washington, 
D.C.: June 20, 2006. 

Results-Oriented Government: Practices That Can Help Enhance and 
Sustain Collaboration among Federal Agencies, [hyperlink, 
http://www.gao.gov/products/GAO-06-15]. Washington, D.C.: October 21, 
2005. 

Vocational Rehabilitation: Better Measures and Monitoring Could 
Improve Performance of the VR Program. [hyperlink, 
http://www.gao.gov/products/GAO-05-865]. Washington, D.C.: September 
23, 2005. 

Federal Disability Assistance: Wide Array of Programs Needs to Be 
Examined in Light of 21st Century Challenges. [hyperlink, 
http://www.gao.gov/products/GAO-05-626]. Washington, D.C.: June 2, 
2005. 

Workforce Investment Act: Labor Has Taken Several Actions to 
Facilitate Access to One-Stops for Persons with Disabilities, but 
These Efforts May Not Be Sufficient. [hyperlink, 
http://www.gao.gov/products/GAO-05-54]. Washington, D.C.: December 12, 
2004. 

Special Education: Federal Actions Can Assist States in Improving 
Postsecondary Outcomes for Youth. [hyperlink, 
http://www.gao.gov/products/GAO-03-773]. Washington, D.C.: July 31, 
2003. 

[End of section] 

Footnotes: 

[1] In this report, we use the term "transition-age" to refer to youth 
between the ages of 14 and 25. This age range covers youth served by 
the key programs we identified as providing transition services to 
youth with disabilities. 

[2] Pub. L. No. 108-446, 118 Stat. 2647, 2676, § 612(a)(1) (codified 
as amended at 20 U.S.C § 1412(a)(1)). 20 U.S.C. § 
1414(d)(1)(A)(i)(VIII). 

[3] Students remain eligible for transition planning and services, as 
well as other IDEA services, until they graduate from high school with 
a regular high school diploma or exceed the earlier of age 21 or the 
eligibility age for a free appropriate public education under state 
law. While federal law authorizes students to receive a free 
appropriate public education up until age 22, eligibility for students 
aged 18-21 is determined by states. 20 U.S.C. § 1412(a)(1) and 34 
C.F.R. § 300.102 (2011). 

[4] See GAO, People with Disabilities: Federal Programs Could Work 
Together More Efficiently to Promote Employment, [hyperlink, 
http://www.gao.gov/products/GAO/HEHS-96-126] (Washington, D.C.: Sept. 
3, 1996); Highlights of a Forum: Modernizing Federal Disability 
Policy, [hyperlink, http://www.gao.gov/products/GAO-07-934SP] 
(Washington, D.C.: August 2007); Special Education: Federal Actions 
Can Assist States in Improving Postsecondary Outcomes for Youth, 
[hyperlink, http://www.gao.gov/products/GAO-03-773] (Washington, D.C.: 
July 31, 2003); Summary of a GAO Conference: Helping California Youth 
with Disabilities Transition to Work or Postsecondary Education, 
[hyperlink, http://www.gao.gov/products/GAO-06-759SP] (Washington, 
D.C.: June 20, 2006); Federal Disability Programs: More Strategic 
Coordination Could Help Overcome Challenges to Needed Transformation, 
[hyperlink, http://www.gao.gov/products/GAO-08-635] (Washington, D.C.: 
May 20, 2008); Young Adults with Serious Mental Illness: Some States 
and Federal Agencies Are Taking Steps to Address Their Transition 
Challenges, [hyperlink, http://www.gao.gov/products/GAO-08-678] 
(Washington, D.C.: June 23, 2008); and High Risk Series: An Update, 
[hyperlink, http://www.gao.gov/products/GAO-11-278] (Washington, D.C.: 
February 2011). 

[5] GAO publishes a high risk list to focus attention on government 
operations that it identifies as high risk due to their greater 
vulnerabilities to fraud, waste, abuse, and mismanagement or the need 
for transformation to address economy, efficiency, or effectiveness 
challenges. This list is updated biennially to remove areas where 
progress has been made and identify any new areas needing attention by 
Congress and the executive branch. 

[6] In this report, we use the term "transition services" to include 
educational services such as tutoring or study skills assistance, 
school-based work experience programs, assistive technology or 
accommodations; employment services such as vocational training, job 
search assistance, job coaching, or supported employment; or other 
support services such as independent living assistance and skill 
development, transportation, mentoring, benefits counseling, 
information, guidance and referral services, advocacy, or financial 
assistance for adaptive equipment or other assistive technology. 

[7] In this report we use the term "coordination" broadly to include 
interagency activities that others have variously defined as 
"collaboration," "cooperation," "integration," or "networking." 
Although there is no commonly accepted definition of coordination, we 
defined it as any joint activity by two or more organizations that is 
intended to produce more public value than could be produced when the 
organizations act alone. See E. Bardach, Getting Agencies to Work 
Together: The Practice and Theory of Managerial Craftsmanship 
(Washington, D.C.: Brookings Institution, 1998). 

[8] We visited the four states with a relatively large number of 
grants for programs that provide transition services (California, 
Florida, Maryland, and Minnesota) and interviewed officials by phone 
in the state with a relatively small number of grants for programs 
that provide transition services (Nevada). 

[9] IDEA was originally enacted as the Education for All Handicapped 
Children Act. Pub. L. No. 94-142, 89 Stat. 773 (codified as amended at 
20 U.S.C. §§ 1400-1482) (1975). 

[10] 20 U.S.C. § 1414(d). 

[11] Under IDEA, transition services are defined as a coordinated set 
of activities that (1) is designed to be within a results-oriented 
process focused on improving the academic and functional achievement 
of a child with a disability to facilitate the child's movement from 
school to post-school activities; (2) is based on the individual 
child's needs, strengths, preferences, and interests; and (3) includes 
instruction, related services, community experiences, the development 
of employment and other post-school adult living objectives, and when 
appropriate, acquisition of daily living skills and functional 
vocational evaluation. 20 U.S.C. § 1401(34). 

[12] Individuals with Disabilities Education Improvement Act of 2004, 
Pub. L. No. 108-446, sec. 101, § 614(d)(1)(A)(i)(VIII),118 Stat. 2647, 
2709 (codified at 20 U.S.C. § 1414(d)(1)(A)(i)(VIII)). 

[13] 20 U.S.C. § 1414(d)(1)(B)(vii) and 34 C.F.R. § 300.321(b)(1) and 
(3) (2011). In addition to IDEA, other laws support the educational 
needs of students with disabilities. Section 504 of the Rehabilitation 
Act of 1973 prohibits entities that receive federal financial 
assistance, including public and private schools, from discriminating 
on the basis of disability against otherwise qualified individuals 
with disabilities. Pub. L. No. 93-112, § 504, 87 Stat. 355, 394 
(codified as amended at 29 U.S.C. § 794). Regulations implementing 
Section 504 are at 34 C.R.F pt 104 (2011). The Americans with 
Disabilities Act of 1990 prohibits discrimination on the basis of 
disability by public entities and public accommodations, including 
public and private schools, regardless of whether they receive federal 
financial assistance. Pub. L. No 101-336, §§ 201(1), 202, 301(7)(J) 
and 302, 104 Stat. 337, 354 and 355 (codified at 42 U.S.C. §§ 
12131(1), 12132, 12181(7)(J) and 12182). Title II regulations are at 
28 C.F.R. part 35 and Title III regulations at 28 C.F.R. pt 36 (2011). 
The requirements of Section 504 and Titles II and III of the Americans 
with Disabilities Act of 1990 and the rights of students with 
disabilities under them are not addressed in this study. 

[14] 29 U.S.C. §§ 702, 706 and 721(a)(2) and (3). 

[15] 29 U.S.C. § 721(a)(9) and 34 C.F.R. § 361.22(a)(2) (2011). If a 
state VR agency is operating under an order of selection, a plan must 
be developed for students who are eligible to receive services under 
the order of selection prior to when they leave school. A VR agency 
must implement an order of selection when it anticipates it will not 
have sufficient fiscal and/or personnel resources to fully serve all 
eligible individuals. 29 U.S.C. § 721(a)(5) and 34 C.F.R. § 361.36 
(2011). An order of selection consists of priority categories to which 
eligible individuals are assigned based on the significance of their 
disability--individuals with the most significant disabilities are 
selected first for the provision of vocational rehabilitation services. 

[16] 29 U.S.C. § 2841. 

[17] Individuals known as "disabled adult children" can receive 
Disability Insurance benefits if they are age 18 or older, were 
disabled before age 22, and have at least one parent who also receives 
Social Security payments because of retirement or disability or who is 
deceased but worked long enough to be eligible to receive benefits. 20 
C.F.R. § 404.350(a) (2011). The SSI program provides financial 
assistance to eligible individuals who are age 65 or older, blind, or 
disabled, and who have limited income and resources. 42 U.S.C. § 
1381a. Children under age 18 may qualify for SSI benefits if they meet 
SSA's disability definition and financial eligibility requirements. 20 
C.F.R. § 416.906 (2011). SSA is statutorily required to redetermine 
the eligibility of all children receiving these benefits within one 
year of their 18th birthday. 42 U.S.C. § 1382c(a)(3)(H)(iii). 

[18] 42 U.S.C. § 1320b-19. 

[19] 42 U.S.C. § 1396n(c). 

[20] "Habilitation services" are defined as "services designed to 
assist participants in acquiring, retaining, and improving the self-
help, socialization, and adaptive skills necessary to reside 
successfully in home and community-based settings." 42 U.S.C. § 
1396n(c)(5). Habilitation services are flexible in nature, they can be 
day or residential, and they can be specifically designed to fund 
services and supports that help an individual obtain or maintain 
employment. 

[21] [hyperlink, http://www.gao.gov/products/GAO-08-678]; [hyperlink, 
http://www.gao.gov/products/GAO-06-759SP]; and [hyperlink, 
http://www.gao.gov/products/GAO-03-773]. 

[22] In this section, we quantified the challenges identified during 
our interviews as follows: we used "most" if a challenge was mentioned 
in more than 85 percent of our interviews; "many" or "frequently" if a 
challenge was mentioned in over half; "some" if a challenge was 
mentioned in less than half; and "a few" if a challenge was mentioned 
in less than 25 percent of the interviews. 

[23] The term "stakeholders" refers to federal, state, and local 
officials; students and parents; and experts on transition. 

[24] 34 C.F.R. § 300.321(b)(3) (2011). 

[25] 29 U.S.C. § 721(a)(5) and 34 C.F.R. 361.36. According to 
Education officials, 45 VR agencies have implemented an order of 
selection, as required by federal law, because they are unable to 
service all eligible individuals in the state due to their lack of 
financial or staff resources. 

[26] Young adults with disabilities may not be eligible for some adult 
services until they graduate from high school with a regular diploma 
or exceed the age eligibility for a free appropriate public education 
under state law because of "payer of last resort" provisions, which 
specify the order in which funding sources or programs should pay for 
services. For example, both VR and Medicaid function as payers of last 
resort--if another program or funding source (for example IDEA) is 
still available to that individual, that other source must be 
exhausted before VR and Medicaid will pay for services. 29 U.S.C. § 
707 (regarding nonduplication), and 42 U.S.C. § 1396a(a)(25) and 42 
C.F.R. § 433.139(b) (regarding third-party liability) (2011). 

[27] According to HHS officials, Maryland has waivers, Community 
Pathways and New Directions Independence Plus, that can serve 
individuals with developmental disabilities who are under the age of 
21. 

[28] California's Workability program is a school-based work program 
for students with disabilities, designed to offer the opportunity to 
complete high school while obtaining marketable job skills. 

[29] Since the 2004 reauthorization of IDEA, schools have been 
required, beginning no later than the first IEP that will be in effect 
when a student turns 16 years of age, to include in the IEP 
postsecondary goals and the transition services needed to assist the 
student in reaching those goals. Individuals with Disabilities 
Education Improvement Act of 2004, Pub. L. No. 108-446, sec. 101, § 
414(d)(1)(A)(i)(VIII), 118 Stat. 2647, 2709 (codified at 20 U.S.C. § 
1414(d)(1)(A)(i)(VIII)). Furthermore, we were told by state officials 
that some states require that transition planning begin earlier than 
age 16, including four of the five states we contacted, which required 
transition planning to begin at age 14. 

[30] In some states, some students with disabilities receive a 
certificate of completion or other alternatives to a high school 
diploma. 

[31] To prevent curtailment of employment opportunities for 
individuals with disabilities, Labor is authorized under certain 
conditions to issue certificates permitting employers to pay them less 
than the otherwise required minimum wage. 29 U.S.C. § 214(c). 
Sheltered workshops, which are also referred to as work centers, 
exclusively or primarily employ people with disabilities certified to 
be paid less than the otherwise required minimum wage. 

[32] We previously reported that Education does not comprehensively 
measure the performance of VR for certain key populations, including 
transition-age youth. See GAO, Vocational Rehabilitation: Better 
Measures and Monitoring Could Improve the Performance of the VR 
Program, [hyperlink, http://www.gao.gov/products/GAO-05-865] 
(Washington, D.C.: Sept. 23, 2005). 

[33] 29 U.S.C. § 2871(b)(2)(A)(i)(II). 

[34] We previously reported that WIA performance measures can create 
disincentives for one-stop centers to serve clients with disabilities. 
See GAO, Workforce Investment Act: Labor Has Taken Several Actions to 
Facilitate Access to One-Stops for Persons with Disabilities, but 
These Efforts May Not Be Sufficient, [hyperlink, 
http://www.gao.gov/products/GAO-05-54] (Washington, D.C.: Dec. 14, 
2004). 

[35] While some coordination efforts included in this report involve 
other federal agencies, we focused on Education, HHS, Labor, and SSA 
because these four agencies administer the key programs serving 
students in their transition out of high school. 

[36] [hyperlink, http://www.gao.gov/products/GAO-06-15]. 

[37] The Federal Partners in Transition Workgroup focuses on all 
youth, including students, with disabilities. In this report, we refer 
to the group's efforts related to students with disabilities, as 
appropriate, to be consistent with the focus of our review. 

[38] The Student Earned Income Exclusion allows SSA to exclude a 
certain amount of a beneficiary's earned income when determining 
benefits payments. 42 U.S.C. § 1382a(b)(1). This exclusion is one of 
the incentives SSA offers to encourage work among SSI recipients. In 
addition, the Social Security Disability Amendments of 1980 allowed 
for continued payments under VR or a similar program to eligible 
beneficiaries until the completion of the program, beneficiary 
participation ends, or continued participation will not increase the 
likelihood of exit from the disability benefit rolls. Pub. L .No. 96-
265, § 301, 94 Stat. 449-50 (codified as amended at 42 U.S.C. §§ 
425(b) and 1383(b)(6)). Examples of specific programs that trigger 
this provision include Ticket to Work, VR, and special education 
services under IDEA for individuals ages 18 through 21. 

[39] Schedule A hiring authority allows individuals with disabilities 
to apply for a federal appointment through a noncompetitive hiring 
process. 5 C.F.R. § 213.3102(u). (2012). 

[40] The IDEA Partnership is funded by the Office of Special Education 
Programs through the Technical Assistance and Dissemination to Improve 
Services and Results for Children with Disabilities program. 20 U.S.C. 
§ 1463. The partnership brings together representatives from national 
associations, service providers, and agencies that have a vested 
interest in improving results for all students, including those with 
disabilities. 

[41] PROMISE, which was first funded in FY 2012, is a joint initiative 
of Education, HHS, Labor, and SSA. Education officials said they are 
currently in the planning stage of the initiative. 

[42] Mutually reinforcing goals or strategies are designed to help 
align agency activities, core processes, and resources to achieve 
common outcomes. 

[43] [hyperlink, http://www.gao.gov/products/GAO-06-15]. 

[44] 42 U.S.C. § 1382c(a)(3) (defining "disabled" in part as "unable 
to engage in any substantial gainful activity by reason of any 
medically determinable physical impairment). HHS officials said 
parents' fear of losing health insurance benefits for their children 
with disabilities creates a similar disincentive for these youth to 
pursue competitive employment. However, officials said new provisions 
under the Patient Protection and Affordable Care Act that allow 
individuals to remain on their parents' insurance policies until age 
26 could help mitigate this. Pub. L. No. 111-148, sec. 1001, § 2714, 
124 Stat. 119,132 (codified at 42 U.S.C. § 300gg-14). 

[45] The age range for children served through special education under 
IDEA is 3 through 21. 20 U.S.C. § 1412(a)(1)(B). SSI serves children 
from birth to age 18, (42 U.S.C. § 1382c(c)), at which point there 
must be a redetermination as to whether or not they are still eligible 
for SSI benefits as adults (42 U.S.C. § 1382c(a)(3)(H)(iii)). 

[46] Under IDEA, transition services are provided through special 
education and make up a coordinated set of activities that (1) is 
designed to be within a results-oriented process focused on improving 
the academic and functional achievement of a child with a disability 
to facilitate the child's movement from school to post-school 
activities; (2) is based on the individual child's needs, strengths, 
preferences, and interests; and (3) includes instruction, related 
services, community experiences, the development of employment and 
other post-school adult living objectives, and, when appropriate, 
acquisition of daily living skills and functional vocational 
evaluation. 20 U.S.C. § 1401(34). The definitions of transition 
services under IDEA and the Rehabilitation Act of 1973 are very 
similar and there is no statutory definition of transition services 
under SSI. 

[47] Education officials noted that federal agencies have recently 
begun working to improve data collection and sharing. Education also 
updated its regulations on the Family Educational Rights and Privacy 
Act and clarified the means by which education entities, including 
school districts, can collect and share data with other agencies. 76 
Fed. Reg. 75,604 (Dec. 2, 2011) (codified at 34 C.F.R. pt. 99) (2011). 
We also previously reported on efforts to develop statewide 
longitudinal data systems that link education and employment 
databases. See GAO, Postsecondary Education: Many States Collect 
Graduates' Employment Information, but Clearer Guidance on Student 
Privacy Requirements Is Needed, [hyperlink, 
http://www.gao.gov/products/GAO-10-927] (Washington, D.C.: Sept. 27, 
2010), 4. 

[48] 34 C.F.R. § 300.154 (2011). 

[49] [hyperlink, http://www.gao.gov/products/GAO-11-278]. 

[50] According to Education and Labor officials, this framework is 
referred to as the "Guideposts to Success" and was developed by 
Labor's Office of Disability Employment Policy, in collaboration with 
the National Collaborative on Workforce Disability for Youth 
[hyperlink, http://www.ncwd-youth.info/guideposts]. According to Labor 
officials, the framework currently includes the following components 
of a successful transition: school-based preparatory experiences, 
career preparation and work-based learning experiences, youth 
development and leadership, connecting activities, and family 
involvement and supports. 

[51] [hyperlink, http://www.gao.gov/products/GAO-06-15]. 

[52] Labor officials said the intra-agency Youth with Disabilities 
Workgroup tracks progress toward outcomes through an informal internal 
work plan. Officials participate in monthly meetings to discuss status 
updates on policy guidance issuance, leveraging resources, upcoming 
webinars, and innovative initiatives. 

[53] 20 U.S.C. § 1416(b)(2)(C)(ii)(II). 

[54] Part B-SPP/APR Related Requirements, [hyperlink, 
http://www2.ed.gov/policy/speced/guid/idea/bapr/2010/e5-1820-
0624relatedrequirements.pdf]. 

[55] 20 U.S.C. § 1412(a)(12). 

[56] Education officials said they are working with SSA to determine 
how to track outcomes of transition interventions, including 
coordination, in SSA's planned evaluation of the PROMISE initiative. 

[57] CFDA is a government-wide compendium of federal programs, 
projects, services, and activities that provide assistance or benefits 
to the American public. While the General Services Administration 
(GSA) maintains the CFDA system and website, the content of individual 
program descriptions is the responsibility of the agency that has 
issued the program description. The Office of Management and Budget 
serves as an intermediary agent between the federal agencies and GSA 
and provides oversight to the necessary collection of federal domestic 
assistance program data. 

[58] The six federal programs were: Education's Model Comprehensive 
Transition and Postsecondary Programs for Students with Intellectual 
Disabilities, Regional Parent Training and Information Technical 
Assistance Centers, and Rehabilitation Services Administration's 
Parent Information and Training Projects; HHS's Youth Information, 
Training and Resource Centers; Labor's Disability Employment 
Initiative; and SSA's Youth Transition Demonstration Projects. 

[59] In a few states we visited, our interviews with workforce agency 
officials included staff from WIA one-stop centers. 

[60] There were three exceptions: In Florida and California, we did 
not meet with higher education officials, although we did meet with 
two higher education associations in California; and in Maryland we 
did not meet with the state workforce agency, although we obtained 
written responses to our questions from several local workforce 
entities. 

[61] [hyperlink, http://www.gao.gov/products/GAO-06-15]. 

[62] The 21 programs included in this appendix met the specific 
selection criteria described in this appendix. In contrast, the 
programs described in the background section of this report are 
examples of broader programs administered by Education, HHS, Labor, 
and SSA that support transition-age students with disabilities, 
although they may not directly provide transition services. 

[63] We determined key subject terms by inputting basic key words, 
such as 'disability,' 'student,' and 'transition,' into the subject 
terms field of the CFDA advanced search form. This field produced a 
list of searchable subject terms related to each of the basic key 
words. From this list, we selected those subject terms that addressed 
at least two of the following topic areas: (1) disabilities, (2) youth 
or students, (3) vocational rehabilitation, and (4) postsecondary 
education. 

[64] We obtained information on the program title, purpose, services 
provided, and eligibility criteria from CFDA and program websites. We 
asked officials to verify or correct this information and provide 
additional information on funding amounts and recipient data. 

[End of section] 

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