Recommendations for Executive Action

1. Status: Open

   Comments: Education disagreed with this recommendation, noting that state VR agencies have the primary responsibility for determining how best to meet employers' needs, promote mainstream employment, and collaborate with other workforce programs in their states. Education recognized the importance of providing information and technical assistance to state VR agencies to help them serve employers, while stressing that it is a state matter how to best meet the training needs of employers.

   Recommendation: 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)

   Agency Affected: Department of Education

2. Status: Open

   Comments: Education disagreed with this recommendation, noting that state VR agencies have the primary responsibility for determining how best to meet employers' needs, promote mainstream employment, and collaborate with other workforce programs in their states. The agency recognized the importance of expanding career advancement opportunities for individuals with disabilities in accordance with the Rehabilitation Act as amended by WIOA. At the same time, Education said it is up to states to determine how to most effectively disseminate information about their services. Education noted it will 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.

   Recommendation: 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)

   Agency Affected: Department of Education

3. Status: Open

   Comments: Education disagreed with this recommendation. The agency stated that it is a state matter to determine whether an employment location qualifies as an "integrated setting" for the purpose of the 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 will continue to work with the states to determine if additional information would help them assess employment locations.

   Recommendation: 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)

   Agency Affected: Department of Education

4. Status: Open

   Comments: 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 will 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.

   Recommendation: 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)

   Agency Affected: Department of Education

5. Status: Open

   Comments: Education neither agreed nor disagreed with this recommendation. Education said it will work with DOL to ensure that state VR agencies' concerns are considered when the performance measure for effectiveness in serving employers is finalized.

   Recommendation: 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)

   Agency Affected: Department of Education

6. Status: Open

   Comments: DOL agreed with this recommendation. The agency said that local workforce boards and one-stop partners are in the best position to lead employer engagement, but that it will collaborate with federal partners in providing related technical assistance.

   Recommendation: 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)

   Agency Affected: Department of Labor

7. Status: Open

   Comments: DOL agreed with this recommendation and said it will coordinate with Education to ensure state VR agencies' concerns are considered in defining the performance measure.

   Recommendation: 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)

   Agency Affected: Department of Labor

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