ࡱ> +-()*'` 0"bjbj{P{P 7n::%ZZZZZZZn֖֖֖8drnrBB"ddd?.m $(hZo??ooZZdd,ohZdZdoZZd6 Wh&֖פ<B0rZu@A/jroooonnnJRPFnnnRPnnnZZZZZZ NATIONAL REHABILITATION ASSOCIATIONS 2010 Issue Statements  Approved by the National Rehabilitation Associations Board of Directors March 9, 2010 "The National Rehabilitation Association (NRA) is a member organization whose mission is to promote ethical and state of the art practice in rehabilitation with the goal of the personal and economic independence of persons with disabilities." NATIONAL REHABILITATION ASSOCIATION 2010 LEGISLATIVE ISSUE STATEMENTS TABLE OF CONTENTS ISSUE PAGE Keep the Rehabilitation Services Administration in the U.S. Department Of Education 3 Common Performance Measures . 6 Maintain the 18 Months Legislative Language Currently in Title VI of the Rehabilitation Act . 7 Governors Waiver Authority 9 Qualified Rehabilitation Professionals... 11 Infrastructure Funding for the One Stop Centers 15 Placing the State VR Directors on the State and Local Workforce Investment Boards .. 17 Transition.. 18 Downgrading of the Office of the Commissioner of the Rehabilitation Services Administration ... 20 Maintaining Mandatory Funding For Title I .. 22 VR and Business -- Partners in Employment 25 The Community Choice Act ..... 28 Specialized Services for Blind Individuals ... 31 American Indian VR Services Program. 32 Maintain Separate Funding for Supported Employment, Projects With Industry and Migrant and Seasonal Farmworkers ................. 33 KEEP THE PROMISE OF THE CONTINUUM KEEP THE HOPE OF MILLIONS OF DESERVING INDIVIDUALS WITH DISABILITIES KEEP THE REHABILITATION SERVICES ADMINISTRATION IN THE U.S. DEPARTMENT OF EDUCATION STATEMENT OF ISSUE The Rehabilitation Services Administration (RSA) currently resides in the U.S. Department of Education, where it has since the U.S. Department of Education became a Cabinet-level Department. The Commissioner of the Rehabilitation Services Administration is a Presidentially-appointed individual who is confirmed by the fullU.S. Senate and is almost always an individual with a significantdisability. Concerns have resurfaced recently that an effort may be under way by some to move RSA from the U.S. Department of Education to the U.S. Department of Labor. We believe moving RSA from the U.S. Department of Education to the U.S. Department of Labor to be misguided and unwarranted because, as we explain further on in this Issues Statement, we believe it is important to retain the continuum of services and supports which students with disabilities receive astheir civil right under the Individuals with Disabilities Education Act (IDEA). Relatedly, we recognize the differences in paradigms of service between the two Departmentsregarding individuals with disabilities; the Department of Labor retains a much more genericmodel which emphasizes a one-size-fits-all approach to securing employment, while the U.S. Department of Education emphasizes an individualized, comprehensive approach to the eligible individual in securing what we consider to be the three Cs of success: College; Careers and Community living. BACKGROUND AND DISCUSSION The Rehabilitation Services Administration has principal responsibility for administering the programs under the Rehabilitation Act of 1973, as amended, (hereinafter referred to as the Rehabilitation Act). These vital programs provide services and supports by qualified rehabilitation counselors to millions of eligible individuals with disabilities and provide the critical continuum from special education to college, careers and community living. No one can dispute the inextricable link between education and careers. The architects of the Rehabilitation Act envisioned this continuum of services and supports to be in the bestinterests of the individual receiving these services. Everything revolved around the individual securing an education -- an education, in conjunction with the individual's self-determination -- that would lead to economic and personal independence. The programs under the Rehabilitation Act provide an individualized approach to the person receiving the services -- not a one-size-fits-all approach -- which, we emphasize, many of the generic job training programs housed in the U.S. Department of Labor provide.Congressional and community architects of the Actappreciated this distinction and this is the very reason why the Rehabilitation Services Administrationrightfully resides and should remain in the U.S. Department of Education. We also note that most of the individuals seeking employment services from the programs under the U.S. Department of Labor are not individuals with disabilities. A generic model may work for many job seekers, but history has borne out that a generic employmentapproach does not work for individuals with disabilities. We can go back as far as the 1950s when we had the Manpower programs, or in the 60s when we had the CETA programs, or in the 70s and 80s when we had the Job Training Partnership Act (JTPA) programs and find that none of these programs, as hopeful and sincere as some in our country were, could achieve successful employment outcomes for individuals with disabilities. The programs administered under the Rehabilitation Act provide services and supports by qualified public and private rehabilitation providers, many of whom hold Master's degrees in the disciplines that make a difference in the lives of individuals with disabilities -- vocational rehabilitation, vocational assessment, and job development and placement. There are studies that show that professionals with Master's degrees have greater success in assisting individuals with disabilities become employed, which are discussed in great detailin the Issues Statement entitled The Qualified Rehabilitation Professional -- Valuing the Rehabilitation Counselor. One final note and we assure you that this gives us no solace to say, but needs to be said. The U.S. Department of Labor has had over 11 years to make the one-stop centers accessible to all individuals with disabilities and, although some strides have been made, the one-stops remain -- to this day -- largely inaccessible to many individuals with disabilities and that is simply unacceptable. RECOMMENDATION For the referenced reasons, the National Rehabilitation Association strongly supports keeping the Rehabilitation Services Administration in the U.S. Department of Education and will oppose any attempt to move RSA to the U.S. Department of Labor. We are confident that the new Commissioner of RSA, Lynnae Ruttledge, is aware of and sensitive to this issue. The Rehabilitation Services Administration has not had a permanent Commissioner since the unfortunate departure of Commissioner Joanne Wilson over 5 years ago. People with disabilities -- just like many others -- deserve to be represented by a Presidentially-appointed U.S. Senate-confirmed individual as the Congressional and community architects of the Rehabilitation Act intended. The National Rehabilitation Association is pleased that Commissioner Ruttledge has the extensive experience and skills needed to administer and advocate for the programs under the Rehabilitation Act which have served and continue to serve annuallymillions of eligible individuals with disabilities. The National Rehabilitation Association isconfident that Commissioner Ruttledge will have the power, persistence and resolve to express that advocacy in a meaningful manner to all in the U.S. Department of Education and beyond. COMMON PERFORMANCE MEASURES STATEMENT OF ISSUE Individuals with disabilities, especially those with significant disabilities, who want theopportunity for a career and living as independently as they wish in their communities, encounter numerous barriers to employment. The "efficiency" measure in the Workforce Investment Act (WIA) Common Performance Measures simply does not take into account the multiple barriers that individuals with disabilities -- especially those with significant disabilities -- encounter in securing and/or retaining employment. The 'efficiency" measure by its very name and nature suggests a one-size-fits-all approach to employment. This approach is contrary to the paradigm of the public/private/State/Federal Vocational Rehabilitation Program which has a dual customer: The individual and the business community. BACKGROUND AND DISCUSSION The VR Program is a comprehensive set of services and supportsto eligibleindividuals with disabilities seeking the American Dream. One of the major benefits of the VR program is the employmentassistance it provides to eligibleindividuals with disabilities enabling them tobecome taxpaying citizens of our great country. The VR program does not -- and should not -- ever allow itself to be coerced into a any-job-will-do mindset in order to meet rigid efficiency measures. All workers in America deserve the best training for the best jobs that this country has to offer. That training should be fully funded and should take into consideration those individuals who need comprehensiveservices and supports to assist them in succeeding in the world of work. As history has borne out, the quick, cheap employment placement has neither served American workers nor this country well in its quest to compete in an increasingly global economy. RECOMMENDATION The National Rehabilitation Association supports the removalor restructuring ofthe efficiency measure in WIA's Common Performance Measures to reflect an increasingly diversified workforce, which includes individuals with disabilities. MAINTAIN THE 18 MONTHS LEGISLATIVE LANGUAGE CURRENTLY IN TITLE VI OF THE REHABILITATION ACT STATEMENT OF ISSUE There is currently in the Rehabilitation Act of 1973 (hereinafter referred to as the Rehabilitation Act) legislative language in Title VI, Supported Employment, that provides for up to 18 months of supports and services to an eligible individuals with disabilitiesunless that timeline is extended by mutual agreement between the eligible individual receiving the services and the rehabilitation counselor. There are some in the community that would like to remove the up to18 months language inTitle VI of the Rehabilitation Act which the National Rehabilitation Association thinks is unnecessary since the 18 months can be waived on a case-by-case basis. BACKGROUND AND DISCUSSION There is currently in the Rehabilitation Act legislative language under Title VI, the Supported Employment title which states: "Supported Employment Services. The term "supported employment services" means ongoing support services and other appropriate services needed to support and maintain an individual with the most significant disability in supported employment, that (A) are provided singly or in combination and are organized and made available in such a way as to assist an eligible individual to achieve competitive employment; (B) are based on a determination of the needs of an eligible individual, as specified in an individualized plan for employment; and (C) ARE PROVIDED BY THE DESIGNATED STATE UNIT FOR A PERIOD OF TIME NOT TO EXTEND BEYOND 18 MONTHS UNLESS UNDER SPECIAL CIRCUMSTANCES THE ELIGIBLE INDIVIDUAL AND THE REHABILITATION COUNSELOR OR COORDINATOR INVOLVED JOINTLY AGREE TO EXTEND THE TIME IN ORDER TO ACHIEVE THE REHABILITATION OBJECTIVES IDENTIFIED IN THE INDIVIDUALIZED PLAN FOR EMPLOYMENT." [EMPHASIS SUPPLIED.] The National Rehabilitation Association might support, however, extending the "up to 18 months" language to "up to 24 months" in the Rehabilitation Act, but will not support eliminating the timeline altogether since the timeline can be waived. RECOMMENDATION Because the Rehabilitation Act specifically states that the 18 month timeline may be waived on a case-by-case basis with the mutual agreement of the eligible individual receiving services nd the rehabilitation counselor, the National Rehabilitation Association believes there is no need to remove the 18 months language from the Act, but will consider extending the timeline to up to 24 months. THE GOVERNORS' WAIVER AUTHORITY STATEMENT OF ISSUE In 1998, the Congress linked the programs authorized under the Rehabilitation Act (also known as the Vocational Rehabilitation (VR) program)to the Workforce Investment Act (WIA) with a promise that the Rehabilitation Act would always maintain its own, discrete funding stream. Given that Congressionalguarantee and themillions of eligible individuals with disabilities securing a career and community living from the programs and supports of the VRProgram, the National Rehabilitation Associationdoes not support Governors, the Secretary of the U.S. Department of Labor, or anyone else, having the authority to waive any provision of the Rehabilitation Act of 1973, as amended, an Act which has been carefully crafted over the years by pioneers in the advocacy community and the Congress to ensure that eligible individuals with disabilities have the resources they require to secureemployment that leads to economic independence and community living. BACKGROUND AND DISCUSSION TheCongressional architects of the Workforce Investment Actmade it clear that the programs administered under the Rehabilitation Act of 1973, as amended, would always maintain their own, dedicated funding stream. In the 109th Congress, however, the House WIA reauthorizationbill included a provision allowing the Governors broad waiver authority over all mandatory partner programs inthe Workforce Investment Act, including the Rehabilitation Act of 1973, as amended, the programs under which presentlycomprise Title IV of WIA. Since WIA's original authorization in 1998, the U.S. Congress had cut WIA's funding through funding rescissions in the appropriations bills and in the2007 Labor-HHS-Ed appropriations bill for FY 2008,the rescission in WIA is left to the U.S. Secretary of Labor to determine which States actually have left over funds and how to achieve the fundingreduction with the least disruption to the overallprogram. ManyStates -- and perhaps eventually all States -- have experienced, are continuing to experience, and will continue to experiencebudget shortfalls for the foreseeable future due to the collapse of the mortgage/housing industry and a worseningeconomy-- resulting, together with other, economic factors, in the worst recession we have seen since the Great Depression. While this country is slowly rebounding from the great recession, the recovery is a jobless one, which is further exacerbating the budgets of cash-strapped States. As a result, Governors will be seeking funds from wherever they can get them tocompensate for the significant funding shortfalls in their Statescreatedbythe worst economy that we have experiencedin decades towhich the National Rehabilitation Association is sensitive, but feels strongly that these funding shortfalls should not be done on the backs of individuals with disabilities. The National Rehabilitation Association does not now norhas eversupported taking deserving dollars from individuals with disabilities to pay for States funding shortfalls. Individuals with disabilities -- especially those with significant disabilities -- need and deserve individualized services and supports in order to assist them in achieving the American Dream of going to college, having a career and community living. The Public/Private/State/Federal VR Program provides individualized services and supports by qualified rehabilitation counselors and associated qualified personnel, which in conjunction with the individual's self-determination, has made the American Dream a reality for millions of eligible individuals with disabilities. Moreover, statistics show that individuals with disabilities who enter the workforce with the proper program of supports and services by qualified rehabilitation personnel that the VR Program providesmake an impressive return on investment of Federal dollarsin becomingtaxpaying citizens of our great country, rather than relying on public programs for their livelihood. RECOMMENDATION The National Rehabilitation Association strongly opposes any waiverby the Governors, theSecretary of the U.S. Department of Labor, or anyone else, of any provision of the Rehabilitation Act of 1973, as amended, that would subvert the original intent of Congressin guaranteeing the Rehabilitation Act would always maintainits separate, distinct, funding stream for theeconomic and personal independence ofeligible individuals with disabilitieswhen the Congress linked the Act to the Workforce Investment Act in 1998. QUALIFIED REHABILITATION PROFESSIONAL (With emphasis on valuing the vocational rehabilitation counselor) STATEMENT OF THE ISSUE There is a critical shortage of qualified rehabilitation professionals across the spectrum of disciplines that serve as members of the rehabilitation support team. None is more acute than the need for increased numbers of qualified vocational rehabilitation counselors. Improvements in diagnostic tools and innovations in assistive technology coupled with older workers continuing in the workforce longer, the epidemic in chemical dependency and disabled veterans of the war in Iraq and Afghanistan have increased the demand for services and has exacerbated the shortage of qualified rehabilitation personnel. Further, almost one million individuals receive services annually from the 80 State vocational rehabilitation agencies that employ 9,986 vocational rehabilitation counselors (24,972, all classes of employees) who successfully rehabilitate over 200,000 individuals each year. Federal funding for the education and training of qualified professionals has not increased for more than 15 years, holding steady at about 39 million dollars (Rehabilitation Act of 1973, as amended (hereinafter referred to as the Rehab. Act)). BACKGROUND AND DISCUSSION Federal legislation has acknowledged that disability is a natural part of the human experience (1992 Rehab. Act amendments, Title 1, Section 2). No longer does the challenge rest solely with the individual; it is now an issue for society as a whole. Since 1990 individuals with disabilities have experienced greater community access, more choices, better housing, more accessible transportation, improved education and training, and employment leading to careers (Americans with Disabilities Act, 1990; Rehab. Act amendments, 1992, 1998). Expectations have been raised and a new confidence has emerged in the efficacy of the public-private partnership (State vocational rehabilitation (VR) agencies and the vast network of community rehabilitation programs, both non-profit and for-profit) pivotal to the delivery of quality rehabilitation services. As a result of this positive dynamic there is an escalating and urgent need for knowledgeable, competent and legislatively mandated qualified rehabilitation personnel, especially the vocational rehabilitation counselor. The U. S. Department of Labor (Chao, 2004) identifies vocational rehabilitation as one of the ten fastest growing industries, with a 49 per cent increase in employment projected by 2012. The recent Rehabilitation Services Administration (RSA) national study (Chan, 2004) revealed that the average annual turnover rate of rehabilitation professionals in state VR agencies is approximately 16 per cent. This loss is compounded by expected retirement rates for counselors over the next 3-5 years to exceed 50 per cent. The loss of supervisors and managers is expected to be higher. New personnel will be needed in massive numbers to replace experienced staff that entered VR at the time that professional education and training was initiated by the Vocational Rehab. Act amendments of 1954. Further, the RSA study projected the yearly demand for new masters level counselors in the state-federal VR program is 3,812. The projected masters degree graduates is 6,718 with 1,506 of those being Comprehensive System of Personnel Development (CSPD) counselors (already employed by state VR agencies). Thus, graduates equal 5,212 and those entering VR total 1,606 of the needed 3,812. This represents a current retirement replacement issue that will be compounded in the future. The critical shortage becomes even more acute when reviewing the RSA study findings of the loss of newly hired masters degree counselors who leave because of low salaries. The study shows that the average masters salary is $36,583 in the state-federal VR program falls far below competitive salaries in other agencies. Twenty-six per cent of the counselors are planning to leave State VR agencies voluntarily for higher-paying opportunities. Counselors with less than four years with the VR agency have a higher rate of departure (32%) and those under 40 years of age have even a higher departure rate at 36 per cent (Chan, 2004, Sales, 2006). These data clearly establish at the very least the need for an aggressive, targeted and effective recruitment and retention strategy to minimize any negative impact on the delivery of rehabilitation services to individuals who need them to achieve productivity, independence and inclusion in their community. The Comprehensive System of Personnel Development (CSPD, 1992, 1998) was among the legislative hallmarks of the 1992 Rehab.ilitation Act aAmendments. The provisions require sState VR agencies and their community partners to employ qualified personnel and to upgrade current staff. It was recognized that hiring and retaining qualified personnel is the pathway to quality rehabilitation services and outcomes. The concern about the quality of rehabilitation services continues today as indicated by 2002 federal statistics (OSERS) which indicate that almost half (49.4 %) of new rehabilitation counselors hired by state VR agencies do not meet CSPD minimum qualification standards for that state (Chan, 2004). The rehabilitation field has responded favorably over the years to requests to empirically determine the value of the education level of rehabilitation counselors. The National Council on Rehabilitation Education (NCRE) has sought to document the impact of rehabilitation education on improving the quality of services to individuals with disabilities (Bolton, 1990). A recent meta-analysis (research synthesis) of many studies performed with rehabilitation counselors since 1989 concluded that the overall influence of education level on rehabilitation outcomes is significant at the 95 % level of confidence (Frain, et al, 2006). The report states that consumers who have counselors with masters degrees in rehabilitation counseling achieve better employment outcomes than do consumers with counselors that have other degrees. The studys conclusions lend empirical support to the value of graduate education and training in rehabilitation as a means of producing competent, professionally committed counselors to work in the field of vocational rehabilitation. Finally, it is common knowledge that consumer satisfaction surveys conducted by State Rehabilitation Councils (SRCs) consistently report the enduring value of the counselor as perceived by the individual with a disability. Consumers believe that guidance and counseling provided by the vocational rehabilitation counselor is the single most important service provided by the State vocational rehabilitation agency. RECOMMENDATION There is compelling evidence that 1) public and private rehabilitation programs are facing a critical shortage of qualified rehabilitation professionals, especially masters level vocational rehabilitation counselors employed by state VR agencies, 2) there is a significant and positive relationship between the level of education of the rehabilitation counselor and the quality of consumer outcomes, and 3) there has been no increase in federal funds to support education and training of the individual disciplines represented on the multidisciplinary rehabilitation support team, especially the masters degree vocational rehabilitation counselor. Therefore, it is recommended that 1) NRA should continue and enhance partnerships with cognizant agencies and organizations in the development and implementation of an effective training, recruitment and retention strategy and 2) NRA should continue to advise and educate the responsible committees of the Congress on the need and justification for an immediate $1550,000,000 increase in support of the education and training authorities of The Act (Rehabilitation Act of 1973, as amended, Title III, Section 302). References 1973: Rehabilitation Act of 1973, as amended 1990: Bolton, B. (1990). Research methodology for investigating the relationship between rehabilitation counselor education and client outcomes. Rehabilitation Literature, 4, 79-81. 1990: Americans with Disabilities Act (ADA), July 26, 1990 1992/98: Rehabilitation Act amendments of 1992 and 1998. 2004: Chan, T. (2004). Presentation, Preliminary Findings of RSA National Study on Rehabilitation Counseling. NCRE/RSA/CSAVR National Conference, October 25, 2004. Washington, DC. 2004: Chao, E. (2004). Introduction to Americas Dynamic Workplace, Labor Day Report, U.S. Department of Labor. Washington, DC. 2006 Frain, M. P., Ferrin, J. M., Rosenthal, D. A., & Wampold, B. E. (2006). A meta- analysis of rehabilitation outcomes based on education level of the counselor. J. of Rehabilitation, (72-4), 10-18. 2006: Sales, A. P. (2006). Rehabilitation counselor salary equity task force convened. Contemporary Rehabilitation, (62-2) INFRASTRUCTURE FUNDING STATEMENT OF ISSUE The National Rehabilitation Association (NRA)continues to support the programs administered under the Rehabilitation Act of 1973, as amended, (hereinafter referred to as the Vocational Rehabilitation (VR) Program) as part of the Workforce Investment Act (WIA) on a cost-allocation, Memorandum of Understanding (MOU) basis. While we cautiouslycontinue our support ofthe WIA, wehave serious concerns about thechronic inaccessibility of the one-stops,the underfunding and rescissions to WIA since its authorization in 1998 and the effectchronic inaccessibility and continuedfunding cutswill have, or already have had,onthe VR Program and on individuals with disabilities. BACKGROUND AND DISCUSSION The National Rehabilitation Association believes that VR has been and continues to payits fair share of expenses at the one-stop career centers, especially given that theone-stops are, inmany cases,notserving individuals with disabilities, including individuals with significant disabilities,which was the intent of Congress when itlinked the programs administered under the Rehabilitation Act of 1973, as amended, to WIA. TheVR Program is a State/Federal/public/private program thatis administered under the Rehabilitation Services Administration (RSA)in the U.S. Department of Education. The National Rehabilitation Association recognizes and commends the public/private VRProgram as one of the most successful job training and placement programs in the history of the work world andrecognizes that it has thedocumentation to support this claim. No other career training program has the impressive data that the VR Program has had and continues to have over its 8+ decades in providing careers and independence to eligible individuals with disabilities. The public/private VRprogram hasassisted millions of eligible individuals with disabilities secure, retain and re-gain quality employment. To pay for infrastructure costs at the one-stops, the NRA strongly supports a separate, fully-funded line item in this year's appropriations bills and encourages the authorizing Committees in the House and Senate to authorize this funding in their reauthorization bills, or alternatively given the billions of dollars in job training that was included in H.R. 1, the American Recovery and Reinvestment Act, that some of that substantial money be used to retrofit the one-stops so that all Americans -- including Americans with disabilities -- will have equal physical and programmatic access to the one-stop career centers like their non-disabled peers. The National Rehabilitation Association has had many concerns regarding past versions ofHouse reauthorization bills.Theseconcerns include the adoption ofa bill that would have empowered Governors to take funds from the various job training programs' partners to pay for infrastructure costs on a "proportionate" basis. This additional money would come from administrative funds. The VR Program does not have a cap on its administrative funds which would allow Governors to divert VRmoney that Congress intended to be used to support a program designed specifically to assist individuals with disabilities in securingemployment and independence, rather, as in some cases, than relying on Government subsidies in order to survive. The National Rehabilitation Association continues to be very concerned about the chronic inaccessibility -- both in a programmatic and in some cases, physical regard -- of the one-stop centers and, as we stated above, strongly suggest that some of the billions of dollars included in H.R. 1, the American Recovery and Reinvestment Act, be targeted toward making all one stop career centers fully accessible to all who walk or wheel through their doors. The United States Department of Labor has hadovertwelve years since the enactment of WIA to comply with civil rights laws such as the American With Disabilities Act (ADA) and Sections 504 and 508 of the Rehabilitation Act of 1973, as amended. Yet, to this day, the one-stops remain inaccessible to many individuals with disabilities. Indeed, the Government Accountability Office (GAO) has reported on thechronic inaccessibility of the one-stop centers as a continuing barrier to individuals with disabilities who seek economic and personal independence. RECOMMENDATION The National Rehabilitation Association supports a one-stop career centerwhich recognizes the multiple barriers that individuals with disabilities face -- especially those with significant disabilities -- in entering or re-entering the world of work. NRA believes it is imperative that the U.S. Department of Labor make every effort to assure that all one-stops are fully accessible to ALL individuals with disabilities. The National Rehabilitation Association strongly supports a discrete, fully-funded line item for funding infrastructureat the one-stops which could be realized through the billions of dollars that the one-stop career centerswill receive over the next two years through the American Recovery and Reinvestment Act. PLACING THE STATE VR DIRECTORS ON THE STATE AND LOCAL WORKFORCE BOARDS STATEMENT OF ISSUE The National Rehabilitation Association supports both the State Directors of the General VR (Vocational Rehabilitation) Agencies and the State Directors of the VR Agencies for the Blind, where applicable, to be placed on the State Workforce Investment Boards (SWIB) and on the Local Workforce Investment Boards (WIBs). BACKGROUND AND DISCUSSION In the 109th Congress, the House WIA bill regrettablyremoved the State VR Directors from the local Workforce Investment Boards. The State VR Directors of both the General Agencies and the Agencies for the Blind have the expertise in the VR Program and that expertise must be represented on both the State Workforce Investment Boards and the Local Workforce Investment Boards to ensure that VR funds are directed towardeconomicindependenceof all eligible individuals with disabilities, which the Congress intended. We believe that as a mandatory partner, VR is contributing millions of dollars to the one-stop career centers and must have a strong presence on both the SWIBs and the WIBs in ensuring that individuals with disabilities receive the recognition and respect that they deserve in all decisions made by the State Workforce Boards and the Local Boards. The National Rehabilitation Association strongly believes that in order for you to be a player in the negotiations and decisions that are made regarding individuals with disabilities, the State VR Directors of both the general and, where applicationble, agencies for the blind, mustbe at thetable. RECOMMENDATION: The National Rehabilitation Association strongly supports having both the State VR Director of the General Agencies and the State Director of the VR Agencies for the Blind (where applicable) on both the SWIBs and the WIBs. TRANSITION STATEMENT OF ISSUE The National Rehabilitation Association has always supported, and continues to support, enhancing employment outcomes for eligible transitioning students with disabilitiesand other eligibleyoung adults with disabilitiesinto theworkforce, but maintainsthis enhancement must be accompanied by substantial, additional new moneyover and above the cost of living increase (COLA) authorized and appropriated by the Congress. BACKGROUND AND DISCUSSION In the last Congress' House and Senate Workforce Investment Act (WIA) bills, of which the programs authorized under the Rehabilitation Act of 1973, as amended, comprise Title IV, recommendedusing $50 million dollars in Title I, which is mandatorily funded and automatically receives the Cost of Living Increase (COLA), and putting that money toward enhancing transition outcomes for eligible young adults with disabilities transitioning from school to work. The $50 million set-a-sidewould be taken from Title I funds once the COLA reached $100 million dollars, which is approximately two years in most cases, althoughin 2010 noCOLA was not realized since the rate of inflation was a negative number. With 40 State Agencies on an Order of Selection (which prioritizes that iindividuals with the most significant disabilities be served first) coupled with waiting lists in some States for the excellent and proven services and supports that qualified Rehabilitation Counselors provide in the State VR Agencies, in conjunction with their Community Rehabilitation Programs (CRPs), it is critical that substantial, additional deservingdollars be authorized/appropriated in order to realize enhanced transition outcomes. The unintended consequence of not providing additional funding for transition regrettably pits deserving students and other young adults with disabilities against deserving eligible adults with disabilities. The National Rehabilitation Association recognizes that this is not what Congress intended by including language in both the House and Senate WIA bills last year, but the reality is that this is exactly what will happen if additional funding is not provided for transition. In this same regard, the National Rehabilitation Association does not support placing one category of disability ahead of other categories of disability whose populations are eligible for VR services. Any pittingby category of most significant disability (MSD)will most certainly leave someone behind. As is the case in the Senate discussiondraft of 2008, adults with disabilities would be left behind if transitioning students with disabilities, including those on SSI, were to be placed at the head of the MSD line for services. To do so would turn the VR Program into an entitlement program, which it is not now and which was notCongressional intent. The Rehabilitation Act of 1973, as amended, is an eligibility program for all individuals withdisabilities who meet its eligibility requirements. -- And, ALL MEANS ALL individuals with disabilities, not just a certaincategory population of disability being served. RECOMMENDATION The National Rehabilitation Association strongly supports additional funding for enhanced transition outcomes and strongly recommendsthat an appropriate portion of the $12.2 billion dollars that was approved for the Individuals With Disabilities Education Act (IDEA) in H.R. 1, the American Recovery and Reinvestment Act, be targeted to enhance the numbers of eligible young adults with disabilities transitioning from school to work. The National Rehabilitation Association remains strongly opposed to placing any category of disability over other categories of disability which meet the Rehabilitation Act's eligibility requirements. THE DOWNGRADING OF THE OFFICE OF THE COMMISSIONER OF RSA STATEMENT OF ISSUE In the 109th and110th Congresses, the House version of theWorkforce Investment Act(WIA) reauthorizationbill recommended downgrading the Office of the Commissioner of the Rehabilitation Services Administration (RSA) in the U.S. Department of Education from a Presidential Appointment, confirmed by the full U.S. Senate, to a Directorchosen by the Assistant Secretary of the Office of Special Education and Rehabilitative Services (OSERS). The National Rehabilitation Association is strongly opposed to any downgrading or diminution ofthe RSAwhich is theONLY office in the U.S. Department of Education devoted to the employment of individuals -- including adults --with disabilities. BACKGROUND AND DISCUSSION The National Rehabilitation Association is strongly supportive of the Office of the Commissioner of the Rehabilitation Services Administration remaining a Presidentially-appointed individual with full U.S. Senate confirmation. The National Rehabilitation Association is strongly opposed toany downgrading of any kind of the Commissioner's Office for a number of reasons, including the fact that no one in the Congress, the U.S. Department of Education or anyone else, has given theadvocacy community a reason for downgrading this important Office, which has the principal responsibility forand traditionally the unmatched expertise in the programs administered under the Rehabilitation Act of 1973, as amended. No other office in the U.S. Department of Education has the extensiveexpertise in the VR Programthat the Office of the Commissioner of RSA has had and continues to have, including the Office of the Assistant Secretary in the Office ofSpecial Education and Rehabilitative Services, whose expertise has always been directed in special education, not employment. The Office of the Commissioner of the RSA has traditionally employed more individuals with disabilities than any otherdepartment or agency in the Federal government. Indeed, theCommissioner of RSA, very often a consumer of the VR Program, is the highest ranking official in theAdministration with the expertise in the VR Program. Why would anyone want to downgrade an individual/office who administers one of the most successful career-producing-independence-inducingprogramswhich advocateswith and on behalf ofeligible individuals with disabilities? It simply does not make sense and is, we believe, misguided public policy. The National Rehabilitation Association believes that downgrading the Office of the Commissioner of RSA would diminish the importance of the VR Program and willdevalueindividuals with disabilities, especially adults with disabilities, some of whom were directly responsible for structuring the Office of the Commissioner to be directly responsible to the U.S. Secretary of Education at the level of a Presidential Appointment, with full U.S. Senate confirmation. The National Rehabilitation Associationdid notsupport the 2008 Senate VR reauthorization discussion draftrecommendation of maintaining the Commissioner title butbe directly responsible to the Assistant Secretary of the Office of Special Education and Rehabilitative Services, not the U.S. Secretary of Education. Thisrecommendation, intended to be a compromise, simply retains a title without any power. Nor does the National Rehabilitation Association support the recently introduced House bill, H.R. 4271, which could not only downgrade the Office of the Commissioner of RSA but would also require that $50 million set-aside in Title I of the Rehab Act once the COLA reached $100 million. RECOMMENDATION: Individuals with disabilities, including adults with disabilities,have fought for decades for the right toberespected and represented.All individualsdeserve to be represented -- including adults with disabilities. The Office of the Commissioner of RSA respectsand represents many individuals, includingadults withdisabilities. MAINTAINING MANDATORY FUNDING FOR TITLE I STATEMENT OF ISSUE President Bush's2009 budget proposed to change the funding of Title I of the Rehabilitation Act of 1973, as amended,from a mandatory-funded program to a discretionary-funded program, which willELIMINATE the Cost of LivingAdjustment (COLA)(also known as the Consumer Price Index adjusted for Urban areas or CPIU) from Title Iof the Rehabilitation Act. This potentialloss of millions of dollarswould hurt individuals with disabilities -- many of whom are individuals with significant disabilities --seekingto have a careerandto live as independently as they choosein the community. The President's 2009, 2010and the current President's 2011 budget also recommends the consolidation of funding for Projects With Industry (PWIs), Supported Employment, and Migrants and Seasonal Farm Workers and In-service Training, programs funded under Title VI andTitle IIIof the Rehabilitation Act, by consolidating (eliminating) these programs into Title I of the Rehabilitation Act. Congress, in its infinite wisdom, realized thateliminating(or consolidating) these important programs would have also eliminated $200 million of desperately needed dollars toeligible individuals with disabilities, and did not allow this to happen. BACKGROUND AND DISCUSSION Title I of the Rehab Actprovides the funding, through qualified rehabilitation counselors, for the trainingand employment to eligible individuals with disabilities, including those individuals with significant disabilities. Congress intended that Title I receive thecost of living increase annually to assist in reducing the rate of unemployment among individuals with disabilities who face multiple barriers topursuing careers and living independently in the community. Eliminating the cost-of-living increase will result infewer individuals with disabilities being served by the State/Federal/Public/Private VR program, will result in an even higher rate of unemployment among individuals with disabilities than we have now,and willseriously harm individuals with disabilities some of whom are our returning veterans who seek economic and personal independence. The VR Program has servedmillions of eligible individuals with disabilities over eight-plus decades. And, when we say"served" we mean assisted with career planning,career counseling and development, and employment training and placement byqualified rehabilitation counselors employed in both the public and private sectors. Reducing funding for Title I of the Rehabilitation Actwouldwill forcesome individuals with disabilities who wish to work and live independentlyto seek public assistance becausefewer and fewerindividuals with disabilities will receive services fromthe VR Program. Veterans who bravely serve our Country and are surviving serious injures, thanks to the skilled medical technicians on the battlefield, are returning home with traumatic brain injuries (TBI), as well as Post Traumatic Stress Disorder (PTSD), in greater numbers than the Veterans Department of Veterans Affairs Administration is prepared to handle, according to recent news reports. The VR program has many years of history in understanding and serving persons with TBI, and with adequate funding, can expand its partnership with the VA through memoranda of understanding (MOUs) to serve many of these deserving veterans. We know, too, that the VR Program has an impressive return on investment. Indeed, for every $1 dollar spent in serving SSI/SSDI recipients/beneficiaries, $6 of taxpayer dollars is returned to the U.S. Treasury according to the Social Security Administration. If the Congressdid notmaintain full mandatoryfunding to Title I of the Rehabilitation Act, waiting lists for theproven services and supportsthat theVR Program provideswould have returnedin all States, given the dramatic downturn in our economy and many individuals with disabilitieswould have beenleft behind as the door to the American Dreamclosed. If the Congressdid notmaintain full funding to Title I of the Rehabilitation Act, thousands of individuals with significant disabilitieswould have hadno where to go for services because many times individuals with significant disabilities' services and supports cost more and require the services of staff that are fully qualified to assist those individuals who desire challenging careers and full independence. Employers and businesses tell us through theNational EmploymentNetwork, which has presented at NRA'sLegislative Summit for the past5 years,how important proper training of employees is to them andto the viability of their businesses. Consumers of VR services, coupled with their self-determination, are prepared to tackle the tasks presented to them in an increasingly globalized world because of the services and supports they receivefrom the qualified personnelin the VR Programand their Community Rehabilitation Partners. Businesses want well-trained, reliable employees. The Public/Private VR Program assists consumers to be well-trained and reliable employees for many businesses. Don't let down consumers. Don't let down businesses that need and appreciatewell-trained employees with disabilities. How many times have we heard from consumers of the VR Program at NRA's Government Affairs Summit and in other forums that the services and supports they received provided much-needed hopeto them to live the American Dream. Title I has also experienced increased demands on its funding. Presently, there are 40 State Agencies on an Order of Selection which places a priority on serving individuals with significant disabilities. If Congressever allowedTitle I funding to become a discretionarily funded program (often the first programs to be cut or eliminated especially during an economic downturn), thousands of eligible individuals with disabilities would not be served andwould have no where to go because, as we said, these individuals require multiple supports and services and are most often the most expensive to serve. Moreover,the 2008WIA bills included language in both the House and Senate versions to enhance transition outcomes for eligible students with disabilities, which we support. This language, regrettably, did not include an authorization for appropriations, which has the unintended consequence of pitting deserving, eligible adults(including veterans)with disabilities against deserving, eligible students with disabilities, because there is simply not enough money to serve all of the consumers who are coming to the VR Program for the excellent supports and services they know they will receive. The Individuals with Disabilities Act (IDEA) received $12.2 billion dollars the recently-passed H.R. 1, the American Recovery and Investment Act and we respectfully request that part of that money be used to enhance transition outcomes for eligible young adults and students with disabilities. The State/Federal/Public/Private VR Program is accountable, cost-effective and has an impressive return on investment which is documented in RSA's Longitudinal Study and other RSA data. RECOMMENDATION The National Rehabilitation Association respectfully requeststhe Congress to alwaysmaintainmandatory funding for Title I of the Rehabilitation Act and will seek stronger legislative language in the Rehabilitation Act to preserve this critical mandatory funding.. The National Rehabilitation Association respectfully requests the Congress to alwaysmaintain discrete funding in Titles III andVI of the Rehabilitation Actfor Supported Employment, Projects With Industry (PWIs), and Migrants and Seasonal Farmworkers and Recreation, programs that are complementary to the services and supports provided in Title I of the Rehabilitation Act. VOCATIONAL REHABILITATION AND BUSINESS: PARTNERS IN EMPLOYMENT STATEMENT OF THE ISSUE The Rehabilitation Act of 1973, as Amended (The Act) and the public Vocational Rehabilitation (VR) program established individualization as a hallmark for the provision of services to eligible individuals with disabilities. Yet it is common knowledge that while the VR system is funded to serve the individual, the careers of those individuals and the employment outcomes that the VR system is measured on are tied directly to employers. These employers are represented by private, public and not-for-profit businesses. With unemployment rates at staggering levels it is timely and prudent to make improvements in the ways that VR and business can work together to achieve mutually beneficial goals, objectives and outcomes. To facilitate this change of enhanced philosophy and approach, language should be added to the Rehabilitation Act that strengthens and defines the unique role and partnership that must exist between VR and business. BACKGROUND AND DISCUSSION Through the years, it has been documented by several public surveys, including the Harris Poll, that the number one reason for the high unemployment rate of individuals with disabilities are attitudinal barriers. Individuals who make policy and hiring decisions within companies often do not understand disabilities, have limited exposure to this population, have stereotypes or fears related to the assumed risks and expenses of employing people with disabilities. Though there are laws in place, like the Americans with Disabilities Act, it is not enough. The time spent developing direct working relationships with business, educating hiring authorities and directly supporting these employers is the demonstrated approach that makes a positive difference in the employment of people with disabilities. In order to increase the number of people with disabilities in the workplace, VR must work with business to increase their knowledge and comfort level related to working with employees who have or acquire a disability. VR is able to achieve this through the development of ongoing relationships with business that results in understanding the current or real time employment needs of these business partners. With this level of knowledge, VR is able to build realistic career plans with consumers and refer these qualified candidates to employers while also providing technical assistance and linkages to the resources within the professional network. This approach has proven to be effective in supporting the success of both the individual and the employer. As a customer of VR, the strategies that have proven successful with business involve building a long-term relationship that is founded on an understanding of their employment needs and a level of trust that allows them to seek supports, as needed, without fear of litigation. The VR system is the one nationwide system that has this capability based on the qualifications of staff and access to the largest talent pool of people with disabilities. There is a network of 80 VR agencies across the country, in the territories and the District of Columbia. This network serves approximately one million eligible individuals with disabilities through a comprehensive, person centered career planning approach. This network of agencies includes qualified staff, technical experts and a variety of community partners that are able to coordinate and leverage national resources while having the capacity to deliver locally. Historically, the public VR system has focused on serving the individual with the disability. There had been some VR agencies that work with business but this had been scattered and not a coordinated effort that effectively addressed the employment needs of companies who work in multi-state, national and international markets. Recently, the VR Directors across the country made a commitment to work as one company in serving business through a network of 80 business consultants or points of contact called The National Employment Team (The NET). In a global economy, VR recognized that they must deliver services to business partners in a multi-state and national marketplace. The NET has proven to be an effective strategy for partnering with business to increase the employment of people with disabilities. VR services that have been identified as valued added by NET business partners include: 1) Pre-employment services - connecting future employees with companies through internships, mentoring opportunities and training that is customized to the business need or delivered on-the-job. 2) Recruitment and referral of qualified applicants. 3) Staff training on disability awareness, the Americans with Disabilities Act and other employment laws as well as topics related to disabilities and assistive technology in the workplace. 4) Diversity program strategies that support the inclusion of people with disabilities as customers and employees. 5) Retention programs to support employees who develop or acquire a disability. 6) Consulting, technical assistance and support. a) Workplace accommodations and assistive technology. b) Labor relations, legal, and compliance issues. c) Information technology and the accessibility of internal or external sites, computer hardware and software. d) Accessibility related to contract management and facilities. e) Marketing and customer service to improve services and/or increase the market share of people with disabilities. 7) Financial supports including access to tax credits and/or deductions available for hiring or accommodating people with disabilities. 8) Employee assistance services and program support designed to keep the workforce productive. Though VR partners with a variety of agencies, they must be recognized for their unique niche in the marketplace. Working in a dual customer model requires qualified staff who understands how to train, prepare and support both the employee and the employer. This requires a working knowledge of a variety of factors medical aspects of disability, benefits planning and coordination, independent living, assistive and adaptive technology, reasonable accommodations, employment law, universal design, retention strategies, etc. VR staff and community partners have a unique level of knowledge and expertise that successfully serves this niche in the marketplace. In current law, The Rehabilitation Act of 1973, as amended, has one Section that focuses on the relationship between VR programs and employers. The Rehabilitation Act, Title 1, Section 109, is titled Training of Employers with Respect to Americans with Disabilities Act (ADA) of 1990. Section 109 authorizes State VR agencies to use money received under The Act to train employers on Title I of the ADA and to inform employers about the program and the services available through VR. This limited reference does not fully define VRs role with business and the importance of the programs working relationships with employers. RECOMMENDATIONS NRA strongly believes that to significantly increase the effectiveness of the partnership between employers and VR, The Act must include language that promotes a national support system comprised of qualified VR staff and community partners each uniquely tasked to provide business customers with the qualified candidates, technical assistance and the retention supports they need at the local, state, multi-state and national levels. The national VR network must have the capacity to provide business with ongoing technical assistance, when needed, to support the employee-employer relationship in the long-term. Additionally, The Act must include language that specifically focuses on VRs role with business and employer customers. There should be language on the services identified by business that can best be provided by a national VR network. These are the pivotal services that will enable VR and employers to develop and strengthen their national partnerships and effectively increase the number of individuals with disabilities who are employed in Americas workforce. References The Rehabilitation Act of 1973, as amended. The National Employment Team (The NET): www: rehabnetwork.org/Business Relations; a project of The Council of State Administrators in Vocational Rehabilitation (CSAVR). 32nd Institute on Rehabilitation Issues, The VR-Business Network: Charting Your Course, August 2006. COMMUNITY CHOICE ACT STATEMENT OF THE ISSUE Senator Tom Harkin (D-IA)reintroduced the Community Choice Actin this First Session of the 111th Congress. This legislation, S. 683,would amend Medicaid (Title XIX of the Social Security Act) to mandate state Medicaid coverage of community-based attendant services and supports for certain Medicaid-eligible individuals. Senate hearings were held on September 23, 2007 and the House Energy and Commerce Committee held hearings in January 2008. The 110th Congress did not act on these bills, butwith the reintroduction of this important legislation in the current Congress, we are hopeful that this legislation will one day become the law of the land. BACKGROUND AND DISCUSSION Medicaid was first established in 1965 to fill gaps in the private health insurance system. The Medicaid program is Americas major public health coverage program covering over 58 million individuals, including 8 million persons with disabilities and 6 million low-income frail elderly and disabled Medicare beneficiaries who rely on Medicaid to fill Medicares gaps. (Rowland, 2008). Over the same years that the Medicaid program was in place, legislation was passed by Congress to increase the independence of persons with disabilities. The Rehabilitation Act of 1973, as amended was passed. In 1974 the Individuals with Disabilities Education Act was passed and in 1990 the Americans with Disabilities Act was passed which allowed persons with disabilities to have equal opportunity and the right to fully participate in their communities. In 1997 Medicaid Community-Based Attendant Services and Support Act (MiCASSA) was introduced. The bill was first introduced in the House of Representatives by then Speaker of the House, Newt Gingrich. Medicaid, in its design, rules and procedures, favors placement in institutions over Home and Community Based Services (HCBS). (LaPlante, 2007) MiCASSA, on the other hand, was introduced to advance community-based services and supports which individuals with disabilities much prefer over institutional settings. In 1999 the Supreme Court ruled in Olmstead v. L.C, that the unjustified institutional isolation of persons with disabilities is a form of discrimination and a violation of the American with Disabilities Act. Following the decision, states were required to develop comprehensive effectively working plans for placing qualified persons with disabilities in the most integrated setting appropriate. (Kaiser, 2003). The MiCASSA bills were never passed by Congress and similar legislation was reintroduced in 2007 as the Community Choice Act, which would reform Title XIX of the Social Security Act (Medicaid) by ending the institutional bias that currently exists. The Community Choice Act allows individuals eligible for Nursing Facility Service or Intermediate Care Facilities for the Mentally Retarded (ICF-MR) the opportunity to choose instead a new alternative: Community Based Attendants and Supports. The money would follow the individual. In addition, by providing an enhanced match and grants for the transition to Real Choice before October 2011 when the benefit would become permanent, the Community Choice Act would offer state financial assistance to reform their long term service and support system to provide services in the most integrated setting. The demographics of our country are changing. More individuals are living longer and are desiring and planning to live productive, active lives. In addition, children born with disabilities are living longer and healthier lives with advancements in medicine; and thanks to medical technology, assistive technology as well as other advances, young adults who previously would have died from accidents or illnesses are surviving. (ADAPT, 2008) Community services have been shown to be less expensive on average than institutional services and better liked by individuals. Medicaid enrollees with disabilities who receive long term care services in the community have lower overall per enrollee spending compared to their counterparts in institutional settings. Three-quarters of the 1.2 million enrollees, relying on community based care had an average total spending of $34,930, while per enrollee spending for the disabled using institutional care averaged $76,331 (Kaiser, 2006). In testimony before the Senate Finance Committee in September 2007, Senator Tom Harkin (D-IA) testified that -- Federal Medicaid policy should reflect the goals and ideals enshrined in the Americans with Disabilities Act: that Americans with disabilities should have equal opportunity, and the right to fully participate in their communitiesWith appropriate community based services, we can transform the lives of persons with significant disabilities. They can live with family, not strangers. They can be the neighbor down the street, not the person warehoused down the hallThis is the bare minimum that we should demand for every human being in our society. (Harkin, 2007) RECOMMENDATIONS The National Rehabilitation Association calls upon Congress topass and enact, S. 683,the Community Choice Act of 2010. The institutional bias that exists in Title XIX of the Social Security Act must be eliminated. The Community Choice Act should reflect the goals and ideals of the Americans with Disabilities Act, that individuals with disabilities should have the equal opportunity and the right to fully participate in their communities. This is fiscally responsible legislation. Once passed and enacted, the Community Choice Act will save the Federal government money while providing the much preferred option of living and participating in ones own community. It will also provide real choice for long term care to allow for dignity, respect and independence of persons with disabilities. References: 2003 Medicaids Role for People with Disabilities, Kaiser Commission on Medicaid and the Uninsured, 2003 2006 Medicaids Long Term Care Beneficiaries: An Analysis of Spending Patterns, Anna Sommers and Mindy Cohen, The Urban Institute, and Molly O Malley, Kaiser Commission on Medicaid and the Uninsured, Issue Paper, November 2006. 2007 Senator Tom Harkin, Testimony before the Senate Finance Committee: Home and Community Based Care: Expanding Options for Long Term Care, September 25, 2007 Mitchell LaPlante, Ph.D., Associate Professor, University of California, San Francisco, Testimony, Senate Finance Committee Hearing on Home and Community Based Care: Expanding Options for Long Term Care, September 25, 2007 2008 Diane Rowland, Sc.D., Executive Vice President, Henry J. Kaiser Foundation and Executive Director, Kaiser Commission on Medicaid And the Uninsured, Testimony, US House of Representatives, Committee On Energy and Commerce, Subcommittee on Health, Helping Families with Needed Care: Medicaids Critical Role for Americans with Disabilities, January 16, 2008. A Vision for Attendant Services and Supports for the New Millennium, Community Choice Act, ADAPT, 2008. SPECIALIZED SERVICES FOR BLIND INDIVIDUALS STATEMENT OF ISSUE The National Rehabilitation Associations wishes to support the following three issues as submitted by the National Council of State Agencies for the Blind (NCSAB) with regard to the reauthorization of the Rehabilitation Act: BACKGROUND AND DISCUSSION (1) Maintain the option for states to have a separate agency for the blind. Research data and RSA Performance Standards and Evaluation Indicators consistently show that blind and visually impaired individuals achieve better employment outcomes when served by specialized vocational rehabilitation agencies for the blind. The NCSAB strongly supports retaining the authority of states to operate vocational rehabilitation programs for the blind under a separate designated state unit as authorized under Section (101)(a)(2)(A) of the Act. Access to specialized services is an important element in the concept of consumer choice and flexibility. (2) Expand funding for training programs in blindness rehabilitation and reinstitute an RRTC on blindness and low vision. Most consumers who are blind prefer to receive vocational rehabilitation services from professionals trained to work with persons who are blind and from agencies specializing in this service area. Accordingly, the NCSAB urges support for specialized services for the blind through expanded funding of innovative training programs in blindness rehabilitation. Specifically, the NCSAB believes that a Research and Training Center on blindness and low vision should be reinstituted and that rehabilitation counseling and rehabilitation teaching programs continue to be supported. (3) Amend the formula for the distribution of funds under Title VII, Chapter 2. The NCSAB would like to see assurances in the Rehabilitation Act for minimal COLA Increases to all states when additional funds are appropriated for Title VII, Chapter 2 [Independent Living for Older Blind Individuals] and see the base award for each state raised to $350,000. Many states have had funding for Older Blind services frozen for many years. Raising the minimum allotment would assist low population states to better meet the needs of older blind individuals. AMERICAN INDIAN VOCATIONAL REHABILITATION SERVICES (AIVRS) PROGRAM STATEMENT OF ISSUE The National Rehabilitation Association recommends that the AIVRS Projects, once funded, continue to be funded based on decisions from monitoring and technical assistance, rather than competing for continuance every five years. This funding strategy is similar to funding the Centers for Independent Living in Section 722(e)(1) in the Rehabilitation Act. BACKGROUND AND DISCUSSION The AIVRS Projects provide comprehensive vocational rehabilitation (VR) services comparable to the State VR agencies. They apply eligibility criteria and deliver services based on Individualized Plans for Employment as prescribed in Section 102 of the RehabilitationAct. Most AIVRS consumers pursue employment outcomes that require multi-year plans. Individuals receiving services under an Individualized Plan for Employment (IPE) need their future outcomessafeguarded by continuing the projects that service them. Each year, one or two existing projects are not refunded utilizing the peer review process. The Rehabilitation Services Administration (RSA)has indicated that the projects that have not been refunded are substantially performing according to the provision of law and regulations. RECOMMENDATION Accordingly, the National Rehabilitation Association recommends the RehabilitationActinclude legislative language authorizing a 5 -year funding plan enjoyed by the Centers for Independent Living.We recommend that an application approved under this part that complies with the program requirements set forth in the regulations promulgated to carry out this part shall be effective for 5 years and shall be renewed for additional 5-year periods through demonstrated acceptable performance and the submission of a continuation plan, including a proposed budget, to the Commissioner of RSA for approval. The plan would identify, at a minimum, future performance criteria, goals and objectives. MAINTAIN DISCRETE FUNDING FOR SUPPORTED EMPLOYMENT, PROJECTS WITH INDUSTRY, IN-SERVICE TRAINING,AND MIGRANT AND SEASONAL FARM WORKERS STATEMENT OF ISSUE The President's 2011 Federal budget recommendsconsolidating four important job training and placementprograms which currently have discrete funding in Titles III and VI, respectively. Rather than continuing discrete funding for these performing programs, the President's budget recommends that they be consolidated into Title I of the Rehabilitation Act. BACKGROUND AND DISCUSSION The National Rehabilitation Association notes that Administration based its recommendationsfor the consolidation of these programsbecause they were duplicative of the State VR program and served the same group of individuals. The National Rehabilitation Association cannot support the consolidation of these important programs because we believe these programs complement -- rather than duplicate -- those services provided in Title I of the Rehabilitation Act. A hallmark of the Projects With Industry is the hands-on involvement of community business leaders in preparing and assisting individuals with significant disabilities to achieve competitive employment. PWIs require a match of at least 20%. Currently this match is provided by private donations from the PWI project and its business partners through its Business Advisory Council. If these funds were to be consolidated into the Title I of the Rehabilitation Act the State would have to match the funds, potentially at an even higher rate which in these continuing recessionary times would create a financial burden on already cash-strapped States. The Supported Employment Program assists individuals with the most significant disabilities in securing competitive employmentby providing an array of services and supports, including job coaches. Presently, the Supported Employment Program does not require a State match. Should the Supported Employment Program be consolidated in to Title I of the Rehabilitation Actthatwould change and the Supported Employment grants would have to be matched by already cash-strapped States, most of which must balance their budgets on an annual basis. The Migrant and Seasonal Farm Worker Program assists some of the most under-represented populations in our country -- Native Americans and Seasonal Farmworkers, the latter of whom are critical to the livelihood of many of crop-producing States. If the Migrant and Seasonal Farm Workers program were to be consolidated into Title I, many of these individuals with disabilities would be left behind. RECOMMENDATION The National Rehabilitation Association strongly recommends maintaining discrete funding in TitleVI of the Rehabilitation Act for Supported Employment, Projects With Industry and Migrant and Seasonal Farmworkers.     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