Today the committee released its final report to the USA Secretary of Labor. Established in September 2014, the primary purpose of the work of the Committee was to address issues, and make recommendations, to improve the employment participation of people with I/DD and others with significant disabilities by ensuring opportunities for Competitive Integrated Employment (CIE). This is a brief summary highlighting what are to me some of the key points.
The committee define competitive integrated employment as work performed on a full or part-time basis (including self-employment) for which an individual is:
1. Compensated at not less than federal minimum wage requirements or state or local minimum wage law (whichever is higher) and not less than the customary rate paid by the employer for the same or similar work performed by other individuals without disabilities;
2. At a location where the employee interacts with other persons who do not have disabilities (not including supervisory personnel or individuals who are providing services to such employee) to the same extent that individuals who do not have disabilities and who are in comparable positions interact with other persons; and
3. Presented, as appropriate, with opportunities for advancement that are similar to those offered other employees who are not individuals with disabilities and who have similar positions.
The report noted that; Increasing CIE for individuals with I/DD as well as those with other significant disabilities is a widely shared goal, but one for which a truly comprehensive federal strategy has yet to be defined and implemented.
For people with I/DD or other significant disabilities, center-based employment, also called sheltered workshops, have long been used as a place to provide “prevocational” services for people deemed as either unemployable in CIE or as “needing training” to prepare them for eventual CIE in their communities.
However, center-based employment has been shown to rarely result in CIE, and most participants in center-based employment are paid substantially below minimum wage. Currently, an estimated 228,600 people with I/DD and other significant disabilities are being paid subminimum wage under certificates issued by the U.S. Department of Labor (DOL) Wage and Hour Division (WHD).
Consistent with what evidence tells us, they report; ”Models have shown repeatedly that people previously considered ‘unemployable’ can work, can be productive and can achieve independence. Thus, investing in this approach is a wise use of public funds.” In light of these truths, finding ways to make CIE accessible for individuals with I/DD and other significant disabilities should be a shared priority of federal and state governments and disability community stakeholders.“
“Creating opportunities, removing barriers, and expecting a substantial improvement in the workforce participation rate of individuals with I/DD and other significant disabilities are all essential elements to ensure full economic participation and self-sufficiency. Working adults with disabilities are two times more likely to be living in poverty than their non-disabled peers. CIE is a pathway out of poverty that changes expectations about income production, savings, and economic mobility.”
In the area of practice implementation consistent with our research they note that the application of evince based practice is sketchy at best. It’s not uncommon to find services that state they are one thing actually just using the term to mask what is essentially “their version of evidence based practice.”
They reported; “Even when services are intended to result in CIE, the design and implementation of services are not reflective of Evidence Based Practice (EBP), that is, practice grounded in research and shown to be effective. For example, there is considerable research support for providing experience in community-based workplaces performing actual work tasks as a tool for exposing individuals to career and employment options and as a way of determining work preferences and teaching work skills.”
“However, this EBP strategy is inconsistently applied, or alternative and ineffective strategies are employed, such as “work readiness training” in sheltered workshops, which compounds the ongoing challenge service providers face in successfully engaging employers who might hire individuals with significant disabilities. These circumstances point to an obvious need for elevating the skills of practitioners in the field who are supporting individuals with significant disabilities in seeking and obtaining CIE.“
“Delivering services that result in CIE requires a highly skilled workforce reaching a standard that has yet to be set nationally. In order to develop this workforce there needs to be access to quality training and a rebalancing of funding to pay professional wages that acknowledge the need for high standards to achieve high CIE outcomes.”
In the area of workforce development they made a number of recommendations such as;
CIE capacity-building for service provider staff needs to be driven by a common standard by which performance can be developed, supported and measured so that:
i. Pre-service and in-service training, ideally framed by certification standards, and technical assistance related to the expectation, value and outcome of CIE and skill development to facilitate CIE is provided at various levels, including:
1. Workforce development/employment and education/training service staff of all WIOA core programs and key partners at all levels of employment (i.e. executive, supervisory, and direct service personnel)
2. State agency workforce development/employment and education/training vendors
3. Certification, licensing, and quality assurance personnel associated with respective state agency workforce development/employment and education/training partners
4. Teachers and educators at all levels (early learning, pre-K, K-12, special education, higher education), and
5. Medical professionals who treat individuals with disabilities, including individuals with acquired disabilities (e.g. doctors, nurses, physical therapists, occupational therapists, speech therapists, medical specialists, trauma medical staff, etc.)
ii. Pay scales for disability support professionals take into account certification standards so that these professionals are compensated at a rate that reflects their responsibility and expected competence in delivering services that support CIE. An effective employment system that supports CIE is contingent on the performance and retention of skilled disability support staff. The return on the federal investment in services that support CIE is consequently enhanced.
Additionally the following was recommended;
a. Nationwide web-based, centralized instruction must be developed and implemented in order to mandate that all public workforce system employment services personnel become certified to ensure the continuity of the provision of quality services to businesses and people with disabilities, in particular to people with I/DD and significant disabilities.
b. Educational online initiatives should include, but not be limited to: all employment services personnel within the public workforce system and directed to AJC management and staff, business service representatives, Workforce Development Board members and staff, state workforce executives, and vocational rehabilitation staff.
c. Leads to a certification credential for both current and new employment services personnel working within the public workforce system
d. Certification requirements should build on existing standards, such as those established by the Association for Persons Supporting Employment First (APSE) Certified Employment Support Professional (CESP) exam, and augment any other existing professional standard requirements, e.g., Certified Rehabilitation Counselor
Certification and appropriate remuneration have been discussion points domestically for some time.
Significant among the recommendations was that transition service should start at the age of 14, something that I’ve long believed would rid our current system of the inconsistencies that abound in the delivery of school transition services. It is suggested that:
1. Students with significant disabilities to leave school either employed or with a post-school employment plan that leads to employment;
2. Students with significant disabilities to participate in transition programs that include integrated work experience, internships, apprenticeships or similar job experiences.
Additionally they recommend;
a. setting of transition goals that are based on CIE first and “presumed employability” of all individuals,
b. a requirement for a minimum of one competitive integrated job prior to high school exit that is documented as a transition service,
c. required participation of both the state vocational rehabilitation services agency and the state intellectual/developmental disabilities agency at Individualized Education Program (IEP) meetings of transition-age youth, and/or or other agencies responsible for providing or paying for transition services,
d. prohibition of Section14(c). subminimum wage employment or services as an allowable transition service or post-school outcome, and
e. the age of concentrated transition planning to begin no later than 14.
Families should also be supported through the following measures;
i. Information to families of students with disabilities about strong predictors of post-school success, to include paid, community-based, integrated work experiences prior to school exit.
ii. Family engagement strategies to include:
1. support for the whole family in working toward shared goals for their children,
2. a clear role for family participation,
3. a role for successfully-employed self-advocates and their families to mentor students and their families from diverse cultures who are learning about their own possible career pathways,
4. career exploration opportunities,
5. building students’ self-advocacy and self-determination skills, including making informed financial decisions and improving financial capability,
6. progress monitoring at key transition stages en route to achieving job of choice (from early intervention, middle school, high school, to post- school, and including CIE and postsecondary education), and
7. sensitivity to cultural diversity among families.
This is a detailed report running in excess of 100 pages and well worth reading.