The Arc of Indiana

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For people with intellectual and developmental disabilities

Comments on VR Order of Selection Proposal

The Arc of Indiana submitted the following comments on Indiana Vocational Rehabilitation’s draft amendment to the Vocational Rehabilitation Services portion of the Workforce Innovation and Opportunity Act (WIOA) Unified State Plan.  

The Arc of Indiana is a state-wide organization that advocates on issues important to people with intellectual and other developmental disabilities (I/DD). It is our mission to help people with disabilities realize their goals of living, learning, working and fully participating in the community. The Arc of Indiana has 43 local chapters throughout the state representing 58 counties and over 27,000 individual members. The Arc was established in 1956 by parents of children with I/DD who joined together to build a better and more accepting world for  their children. Today, the combined strength of local Arcs, state Arcs and The Arc of the United States makes The Arc the largest national community-based organization advocating for and serving people with intellectual and developmental disabilities and their families.

We appreciate the opportunity to provide comments regarding the draft amendment to the VR services portion of the WIOA Unified State Plan. We know there has been a lot of conversations taking place regarding these issues and we appreciate the Division’s openness in those conversations and sincerely hope that our feedback and thoughts will be seriously considered. We also want to take a moment to recognize the efforts made to improve the VR process over the last few years. We understand the shortage of the work force and the constraints of revenue and support changes you have made in the past to improve the process.

The Arc of Indiana has a deep commitment to help people with I/DD have access to jobs and careers. When we talk with families and self-advocates, jobs are the top priority of what they want to have as much independence as they can. The services available from BRS play a critical role in assisting people with disabilities entering the workforce. For that reason and certainly others, The Arc of Indiana is concerned about the impact of implementing Order of Selection in Indiana and feels there will be negative implications with the implementation.   

We have concerns about the implementation of Order of Selection as the state places emphasis on the LifeCourse Framework and Employment First policies. In addition, the implementation of the HCBS Rule and WIOA seems contradictory to the Order of Selection process.  As the state of Indiana enjoys a 4.1% unemployment rate, we feel that rate will increase with the number of people with disabilities unable to access employment under the Order of Selection process. In addition, people with disabilities who are able to find work make significant contributions back to the economy by paying taxes and having lessened dependence on other government assistance.

Over the last several years, The Arc of Indiana and its chapters have worked tirelessly to raise awareness to employers about the untapped labor pool people with disabilities provide. We have seen an increase in interest from perspective employers to learn more about hiring people with disabilities as they have learned the positive impact people with disabilities can have in their workforce. We are concerned that now that we have opened this important line of communication, we will not be able to meet the demand for employees that Hoosier employers have.

DDRS and BRS documents have explained that a State Vocational Rehabilitation agency is required to implement an order of selection when it lacks sufficient resources to fully serve all eligible individuals, in accordance with federal timeliness requirements. You state your primary reason for entering into an order of selection process is due to experiencing a deficit of resources, primarily personnel resources. We strongly encourage trying to fix the shortage of personnel resources in other ways as moving to an order of selection process will not solve that problem and works against important priorities of the current State Administration.

We would suggest some of the following as ways to help with workforce issues and offer ourselves and our chapters as potential partners in any way appropriate:

  • Work with the state legislature and/or state budget agency to provide additional funding to VR to draw down more funds from RSA with an effort to reclassify VR counselors to a higher rate of pay.
  • Host a series of job fairs reaching out to this specific market. Consider hiring people with disabilities to fill open positions. Consider using contractors to provide some necessary services.
  • Recruit for open VR positions with Community Rehabilitation Providers (CRPs). Streamline the onboarding process for VRCs.
  • Look for efficiencies within BDDS and BRS staff.
  • Look at training process and find ways to offer intensive training during onboarding and continue with ongoing training throughout their first year.

Recognizing that Order of Selection may move forward, we would suggest reaching out to the states who have already implemented order of selection to see what outcomes they have seen and if they have words of caution/advice in moving forward.

It is our understanding that one strategy for BRS to provide services to those who do not fall within the most significant disability category is to refer them to the Department of Workforce Development and WorkOne. In our opinion, DWD and WorkOne do not have the appropriate training or knowledge to serve people with disabilities.  Furthermore, as our chapters have reached out to DWD in the past, their experience was that DWD told them they did not know how to serve people with disabilities.  We hope that you have done some outreach to these agencies to prepare them for serving people with disabilities.

Lastly, many Arc chapters were recipients of transition grants and establishment grants which have a strong emphasis on employment and training. We see the outcomes of these grants being extremely difficult to accomplish with the implementation of Order of Selection.

The Arc of Indiana restates our concern with the State moving forward with an Order of Selection process.  We fear that moving to the order of selection process will force many people with disabilities to remain unemployed, stay home with no meaningful activities throughout the day and increase their need for government assistance.  In addition, the state will likely see the unemployment rate for people with disabilities, which has remained at a staggering estimated 78% for over a decade, increase even higher. Efforts the state has made in engaging potential employers and putting policies in place that provides emphasis on “competitive, integrated employment” will be difficult to achieve.

Thank you for the opportunity to share our comments and we would appreciate your consideration. We value our relationship with the division and want to continue to be partners in improving the lives of people with disabilities in the State of Indiana.