Vocational Rehabilitation: Additional Federal Information Could Help States Serve Employers and Find Jobs for People with Disabilities
What GAO Found
State vocational rehabilitation (VR) agencies reported expanding services for employers in order to promote hiring individuals with disabilities in mainstream employment (where they are integrated with employees without disabilities and earn competitive wages), but the Department of Education (Education) has not fully addressed related challenges. Most VR agencies in GAO's survey reported providing specific employer services under the Workforce Innovation and Opportunity Act (WIOA) (see figure). However, many agencies reported challenges meeting employers' needs and promoting mainstream employment. For example, some did not fully understand when they are allowed to help employed individuals with career advancement. Education has provided related guidance, including disseminating information at conferences. However, officials at two of three VR agencies GAO spoke with said more information would be helpful. Increasing access to this information may help more VR agencies understand when they have the option of using VR funds for such services.
Types of Employer Services Provided by Most State Vocational Rehabilitation Agencies
Most VR agencies GAO surveyed reported increasing coordination with other workforce agencies, but some gaps exist in federal guidance intended to enhance coordination. Employers GAO spoke with cited challenges navigating workforce programs, yet few agencies reported documenting roles and responsibilities of the agencies they partner with to work with employers. While Education and the Department of Labor (DOL) have provided some related technical assistance, they have not provided examples of documentation of roles and responsibilities. GAO's prior work has found that such documentation can help improve coordination by clarifying who does what in a partnership.
Education and DOL are piloting three measures of the effectiveness of workforce programs in serving employers: employer penetration (i.e., percentage of employers receiving a service), retention with the same employer, and repeat business customers. However, some VR agencies cited concerns with piloted measures, such as the employer penetration measure not being sufficiently linked to VR core program activities. Taking such concerns into account when finalizing performance measures may result in performance metrics and targets that encourage VR agencies to more effectively serve employers.
Why GAO Did This Study
The VR program, administered by Education and state VR agencies, helps people with disabilities obtain employment. In 2014, WIOA made changes to the VR program, increasing its focus on serving employers, promoting career advancement as part of the broader goal of mainstream employment, and coordinating with other workforce programs. GAO was asked to review the VR program under WIOA.
This report examines (1) the steps VR agencies have taken under WIOA to work with employers and place individuals in mainstream employment, and the extent Education has addressed any challenges; (2) how VR agencies have coordinated with other workforce programs and the extent federal agencies have addressed any challenges; and (3) how federal agencies have measured state VR agencies' efforts to serve employers. GAO surveyed all 79 VR agencies (74 responded); conducted three discussion groups with 36 state VR officials and four with 29 employers that worked with VR; interviewed VR and other workforce officials in three states, selected for geographic dispersion, among other factors; and reviewed relevant federal laws, regulations, and guidance.
Recommendations
GAO is making seven recommendations, including improving information on career advancement and partnerships, and aligning performance measures with activities. DOL agreed, while Education neither agreed nor disagreed with the recommendations, but said it will consider taking steps in response.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Department of Education | The Commissioner of Education's Rehabilitation Services Administration should work with state VR agencies to determine whether and what additional information and assistance VR agencies may find helpful regarding on-demand training, such as online videos, to employers on disability issues. (Recommendation 1) |
Education disagreed with this recommendation, noting that state vocational rehabilitation (VR) agencies have the primary responsibility for determining how best to meet employers' needs, but the agency also recognized the importance of providing information and technical assistance to help VR agencies serve employers. In April 2021, Education told us it had made progress towards determining VR agencies' potential information needs related to on-demand training for employers. The agency reported that it published a blog in November 2019 that solicited feedback from state VR agencies and other stakeholders on questions including whether VR agencies need more information from Education on on-demand training for employers related to disability issues, and if so, what topics and how should the information be disseminated. Education reported receiving 13 sets of responses and that it will use this feedback to inform its development of future technical assistance. We will continue to monitor Education's progress in this area, to determine if it builds on this effort and takes further steps, such as providing additional information to VR agencies related to on-demand training to employers on disability issues.
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| Department of Education | The Commissioner of Education's Rehabilitation Services Administration should work with state VR agencies to determine how to most effectively disseminate information about the circumstances in which individuals who are employed may be eligible for career advancement services. (Recommendation 2) |
Education disagreed with this recommendation, noting that state vocational rehabilitation (VR) agencies have the primary responsibility for determining how best to meet employers' needs. However, the agency also recognized the importance of expanding career advancement opportunities for individuals with disabilities in accordance with the Rehabilitation Act as amended by the Workforce Innovation and Opportunity Act, and said it would continue to work with state VR agencies to determine what additional information may be necessary about the circumstances in which individuals who are employed may be eligible for career advancement services. In April 2021, Education told us it published a blog in November 2019 that solicited feedback from state VR agencies and other stakeholders on questions including whether VR agencies need more information from Education on the provision of career advancement services to individuals with disabilities who are employed, and if so, what topics and how should the information be disseminated. Education reported receiving 13 sets of responses and that it will use this feedback to inform its development of future technical assistance. Moreover, its FY 2021 Monitoring and Assistance Guide, includes career advancement as a focus area in the monitoring and technical assistance it will conduct with states. We will continue to monitor Education's progress in this area, to determine if it builds on these effort and takes further steps, such as taking additional steps to disseminate a different approach to disseminating information on the circumstances in which individuals who are employed may receive career advancement services.
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| Department of Education | The Commissioner of Education's Rehabilitation Services Administration should work with state VR agencies to develop more complete information on when and how VR agencies should assess employment settings, including settings supported by the AbilityOne program, to determine if they meet the definition of competitive integrated employment. (Recommendation 3) |
Education initially disagreed with this recommendation, stating that it is a state matter to determine whether an employment location qualifies as an "integrated setting" for the purpose of the vocational rehabilitation (VR) program, and that it is not Education's role to inform states as to when and how to make such determinations. Nevertheless, Education said it would continue to work with the states to determine if additional information would help them assess employment locations. In April 2021, the agency reported that it had issued a set of frequently asked questions (FAQs) for state VR agencies on March 8, 2021, to clarify certain aspects of the definition of competitive integrated employment. Education said it met with many VR agencies and other stakeholders over three years to learn how they've interpreted the definition of competitive integrated employment, and the new FAQs respond to the concerns and questions raised in these meetings. In particular, these FAQs address the criteria for determining if an employment location is integrated, including how to judge whether an employment setting is one typically found in the community, whether a job position was formed specifically to employ people with disabilities, and whether there is sufficient interaction between people with and without disabilities in the employment settings.
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| Department of Education | The Commissioner of Education's Rehabilitation Services Administration should encourage local areas to clarify and document the roles and responsibilities of partner agencies in working with employers and provide sample language of how local areas may document roles and responsibilities in their MOUs. (Recommendation 4) |
Education neither agreed nor disagreed with this recommendation. Education said it believes that state workforce development agencies are in the best position to lead employer engagement efforts, but would continue to collaborate with other federal partners to provide technical assistance to states in this area, including examples of state- and local-level collaboration on employer engagement. In April 2021, the agency reported that it had posted on a joint Education and DOL technical assistance website-as a model for other workforce areas to consider--a local workforce area memorandum of understanding (MOU) that documents the workforce system partners' roles and responsibilities for engaging with employers. The agency also reported that, through its technical assistance centers, it has supported VR agencies and their workforce partner programs in developing MOUs that document roles and responsibilities for employer engagement. At the same time, Education said it cannot provide guidance to local workforce boards because the statute and regulations governing these boards fall within the purview of DOL. We recognize this constraint, but continue to believe Education can play a more proactive role in encouraging VR agencies to take steps in this area. In order to close the recommendation as implemented, Education should provide GAO documentation that it has issued guidance to VR agencies that encourages them to work with partners to document roles and responsibilities for working with employers.
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| Department of Education | The Commissioner of Education's Rehabilitation Services Administration should, in setting the employer performance measurement approaches with DOL after the pilot is concluded, take into account VR agencies' concerns and key attributes of successful performance measures, including clarity in what is meant by employer services, coverage of the VR agencies' core program activities, and consideration of factors outside of VR agencies' control. (Recommendation 5) |
Education neither agreed nor disagreed with this recommendation, but said it would work with DOL to ensure that state VR agencies' concerns are considered when the performance measure for effectiveness in serving employers is finalized. In April 2021, Education reported that it has taken steps to consider state vocational rehabilitation (VR) agencies' perspectives on the pilot performance measures into account. The contractor that conducted a study of the performance measure pilot interviewed VR agencies to obtain their views, and Education reviewed and commented on the contractor's draft report to ensure it reflected VR agencies' concerns. The contractor's final report, issued in April 2021, discusses the specific areas of concern that VR agencies raised with us and that we highlighted in our recommendation. For example, the report notes that the proposed employer penetration rate measure is potentially problematic because it emphasizes breadth rather than depth in services. This echoes VR agencies' concern that this measure is not well aligned with their core program activities, which compared to other workforce programs focus on more in-depth services to fewer employers. Education said it plans to work with DOL to issue proposed regulations finalizing the performance measure in September 2021. We will continue to monitor the agencies' progress in this area to determine if they build on their efforts so far and take any further actions, such as developing a performance measure that reflects concerns raised by our recommendation.
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| Department of Labor | The Assistant Secretary of DOL's Employment and Training Administration should encourage local areas to clarify and document the roles and responsibilities of partner agencies in working with employers and provide sample language of how local areas may document roles and responsibilities in their MOUs. (Recommendation 6) |
DOL agreed with this recommendation, noting that local workforce boards and one-stop partners are in the best position to lead employer engagement, but that it would collaborate with federal partners in providing related technical assistance and guidance. As of June 2021, DOL had taken a number of steps that fully address this recommendation. In 2019 and 2020, DOL provided resources to help local workforce boards and one-stop partners, including the VR program, develop Memorandums of Understanding (MOUs). For example, a local workforce area MOU documents the workforce system partners' roles and responsibilities for aligning service delivery. DOL posted this MOU on its technical assistance web site, so it is available to other local workforce areas. In January 2021, DOL circulated Training and Employment Notice (TEN) 13-20 to state workforce agencies, state and local workforce boards, and one-stop partners. The TEN calls for greater integrated service delivery to one-stop customers, both job seekers and employers. Specifically, the TEN encourages local workforce areas to document in MOUs the roles and responsibilities of workforce partners in working with employers.
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| Department of Labor | The Assistant Secretary of DOL's Employment and Training Administration should, in setting the employer performance measurement approaches with Education after the pilot is concluded, take into account VR agencies' concerns and key attributes of successful performance measures, including clarity in what is meant by employer services, coverage of the VR agencies' core program activities, and consideration of factors outside of VR agencies' control. (Recommendation 7) |
DOL agreed with this recommendation and said it would coordinate with Education to ensure state vocational rehabilitation (VR) agencies' concerns are considered in defining the performance measure. In April 2021, DOL reported that the contractor that conducted a study of the performance measure pilot collected feedback from state administrators of workforce system core programs, including state VR programs, as well as from national organizations including the organization representing state VR program administrators. The contractor's final report, issued in April 2021, discusses the specific areas of concern that VR agencies raised with us and that we highlighted in our recommendation. For example, the report notes that the proposed employer penetration rate measure is potentially problematic because it emphasizes breadth rather than depth in services. This echoes VR agencies' concern that this measure is not well aligned with their core program activities, which compared to other workforce programs focus on more in-depth services to fewer employers. DOL said this final report, along with other information sources, will be used to establish the performance measure for effectiveness in serving employers. We will continue to monitor the agencies' progress in this area to determine if they build on their efforts so far and take any further actions, such as developing a performance measure that reflects concerns raised by our recommendation.
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