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 initially 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. As of April 2021, the agency took several steps toward working with states and ultimately improving on-demand training to employers. Specifically, via a blog it published in November 2019, Education solicited feedback from state VR agencies and other stakeholders on (among other topics) 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 also reported that it has funded several technical assistance projects to improve state VR agencies' capacity to work with employers. Finally, Education worked with the Consumer Value Store (CVS) to produce an on-demand training-now available online-for employers on customized employment.
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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 initially 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. As of April 2021, the agency took several steps toward assisting states with determining individual eligibility for career advancement services: (1) via a blog it published in November 2019, Education solicited feedback from state VR agencies and other stakeholders on (among other topics) 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; (2) in its FY 2021 Monitoring and Assistance Guide, Education included career advancement as a focus area in the monitoring and technical assistance it will conduct with states; (3) Education funded a technical assistance project to support states' efforts to develop career pathways; and (4) in 2021, the agency funded a Career Advancement Initiative grant, which it says is critical to providing states the resources they need to further career advancement efforts. Education indicated that its support of state VR agencies' career advancement efforts is showing success. For example, a VR recipient who formerly worked for minimum wage at a supermarket completed training in a cybersecurity program, greatly improving his outlook on life and increasing his earning potential.
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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. As of April 2021, the agency took several steps to implement this recommendation. First, Education worked with DOL to develop a Training and Employment Notice (TEN) 13-20 that was sent to state workforce agencies, state and local workforce boards, and one-stop partners in January 2021. The TEN calls for greater integrated service delivery to one-stop customers, both job seekers and employers, and specifically encourages local workforce areas to document in MOUs the roles and responsibilities of workforce partners in working with employers. The TEN was circulated to one-stop partners, including state VR agencies. In April 2021, on a joint Education and DOL technical assistance website, the agency posted a local workforce area memorandum of understanding (MOU) documenting the workforce system partners' roles and responsibilities for engaging with employers as a model for other workforce areas to consider. Finally, the agency 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.
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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) |
The Department of Education (Education) neither agreed nor disagreed with this recommendation, but said it would work with the Department of Labor (DOL) to ensure that state vocational rehabilitation (VR) agencies' concerns are considered when the performance measure for effectiveness in serving employers is finalized. Education and DOL have taken steps to collect and consider VR agencies' views. The departments contracted with the Urban Institute to evaluate the three pilot performance measures they initially proposed and tested, and the resulting evaluation report-issued in January 2021-was based in part on interviews with VR agencies. In September 2022, Education and DOL issued a Notice of Proposed Rulemaking (NPRM) that proposed selecting retention with the same employer as the single measure of effectiveness in serving employers. The NPRM cited evidence from the Urban Institute report as the rationale for this proposal, and discussed how the pilot performance measures relate to the three attributes of successful performance measures we highlighted in our recommendation. For example, with regard to coverage of VR agencies' core program activities, the NPRM said the employer penetration pilot measure is problematic because it focuses on quantity rather than quality or intensity of employer services, echoing VR agencies' concern that this measure does not incentivize the more in-depth relationships with employers that are critical to VR's mission.
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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) |
The Department of Labor (DOL) agreed with this recommendation. DOL and the Department of Education (Education) have taken steps to collect and consider vocational rehabilitation (VR) agencies' views. The departments contracted with the Urban Institute to evaluate the three pilot performance measures they initially proposed and tested, and the resulting evaluation report-issued in January 2021-was based in part on interviews with VR agencies. In September 2022, DOL and Education issued a Notice of Proposed Rulemaking (NPRM) that proposed selecting retention with the same employer as the single measure of effectiveness in serving employers. The NPRM cited evidence from the Urban Institute report as the rationale for this proposal, and discussed how the pilot performance measures relate to the three attributes of successful performance measures we highlighted in our recommendation. For example, with regard to coverage of VR agencies' core program activities, the NPRM said the employer penetration pilot measure is problematic because it focuses on quantity rather than quality or intensity of employer services, echoing VR agencies' concern that this measure does not incentivize the more in-depth relationships with employers that are critical to VR's mission.
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