The Provision of Transition Services to Department of Rehabilitation Consumers Q&A

The purpose of this Question and Answer document is to address DOR’s responsibilities in providing vocational services to transition age youth with disabilities, and to discuss the coordinated planning process necessary to facilitate the intermediate vocational objectives and long-term rehabilitation goals for DOR student/consumers as they leave school.

Table of Contents


What are “Transition Services”?

“Transition services”, as defined by the Rehabilitation Act 34 CFR 361.5 (b)(55) and the Individual with Disabilities Education Act (IDEA), 20 USC 1401(34) are a coordinated set of services that include a provision for post-secondary education, vocational training, integrated employment (including supported employment), continuing and adult education, adult services, independent living, or community participation.
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What is the responsibility of DOR in the transition process?

DOR is required to provide consultation and technical assistance to assist educational agencies in planning for the transition of students with disabilities from school to post-school activities, including vocational rehabilitation services. Additionally, DOR is required to outreach to, and identify, students with disabilities who need transition services. In addition, as further defined in this document, DOR is required to serve transition age students as consumers when they apply for services and meet the eligibility criteria.
The Rehabilitation Act requires that students, with disabilities who are eligible for VR services, do not experience an interruption in services after they leave secondary school settings – thus an eligible student’s Individual Plan for Employment (IPE) should be completed before the student leaves the school system. Therefore, as appropriate, the SVRC will provide vocational counseling and guidance to establish an appropriate vocational goal, as well as, provide job related training, accommodations and technology related to work.
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What is the responsibility of Education in the transition process?

The California Department of Education is the responsible agency for the provision of special education, vocational education, Section 504 and ADA assistance (reasonable accommodation plans), and general education. Local Education Agencies are required to provide educational and transition services for those students served by special education until graduation or exit from the education system by age 22.
In the secondary school system under Special Education, IDEA requires that an Individual Education Plan (IEP) be developed by a team, to review the educational needs of the student with a disability. The team reviews the IEP annually and a reassessment is conducted as necessary. Beginning no later than age 16, the IEP is to include a statement of needed transition services for the student, including, when appropriate, a statement of interagency responsibilities or any needed linkages.
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Are Local Education Agencies required to refer students to DOR?

No. Local Education Agencies (LEAs) are responsible for developing an IEP that meets the unique needs of each individual student, taking into account the students preferences and interests. The LEA is responsible for referring students with disabilities to the most appropriate adult agency or program for transition services. In addition to DOR, such agencies and programs may include youth programs developed under the Workforce Investment Act, One-Stop Centers, Regional Centers, Vocational Education, or Regional Occupational Programs/Centers.
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Are all special education students eligible for DOR services?

Not necessarily. If a student has a disability but does not require DOR services to become employed, he/she would not be eligible for services. Students are deemed eligible for services based on the same factors as any other individual. In addition, since California is under an Order of Selection all students, including those coming from special education, would be required to meet the criteria for severity of disability that is being served by DOR at the time of application.
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Are students with disabilities eligible for transition services if they are not involved with special education programming?

Students with disabilities who do not require, or are not eligible for special education services, may be entitled to disability related accommodations in school as a result of a 504 plan. The 504 plan may or may not specify “transition services” depending on the needs of the student. If the student with a 504 plan is deemed eligible for DOR services, the IPE should be coordinated with the 504 plan.
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What is the SVRC’s role in the IEP process?

When an SVRC is requested to attend an IEP meeting for a student with a disability, who is not a DOR consumer, local discretion may be used when committing staff time. If the SVRC cannot attend an IEP meeting, the SVRC and education staff may wish to explore alternative means by which input from the SVRC can be incorporated in the IEP.
If the student is a DOR consumer, the SVRC should participate in a collaborative team process to assist in the development of the transition services provisions of the IEP and in the development of the IPE. The development of these transition services may occur in an IEP meeting, or other appropriate venues. This collaboration will assist in the coordination of goals, objectives, services and timeframes found in the IEP and IPE. This process should include the involvement of the consumer, family, representatives of the LEA and other service providers.
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When should the SVRC begin to work with a transition age youth with disabilities?

While SVRCs can serve as a resource to the students in early transition planning, they are not expected to attend an IEP or develop an IPE for youth prior to age 16. For students ages 14 through 16, the primary role of the DOR counselor will be to provide general coordination, information, and outreach activities about vocational transition planning. Appropriate service coordination activities include providing resource information about vocational rehabilitation, presentations, and staff development.
In most cases, the SVRC should become involved with the student during the last one to two years of high school. However, the student’s unique needs will determine when DOR becomes involved. High school students who are VR consumers may require services for vocational evaluation, assistance with summer or part time work, or other supports to assist them in moving toward becoming economically self-sufficient.
It is important to note that the responsibility to serve transition age youth applies to VR in general and is not limited to localities where there are Transition Partnership Project cooperative programs. While these programs result in a more intense, enhanced pattern of service, other transitional youth who require VR services should be served by the base VR program.
Pursuant to federal law and regulation, prior to graduation from high school an IPE must be completed for eligible students who apply for VR services. After graduation the SVRC will become more directly involved with the consumer and should take the lead role in the achievement of their employment goal.
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Can DOR utilize existing documentation from the Local Education Agency to assist in the determination of eligibility?

To the maximum extent possible, and with appropriate releases, the SVRC should use existing, current, education assessments from qualified school personnel to assist in the determination of VR eligibility prior to the student’s exiting from the school system. (The IEP itself is not an assessment document, and is not singularly sufficient to establish the existence of a disability.) The intent of using existing documents is to save valuable time and resources while avoiding wasteful duplication.
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Can DOR secure other assessments if the education records are insufficient?

If existing education agency assessments or medical documentation is unavailable, significantly outdated, or insufficient, the SVRC may purchase additional diagnostic services and vocational assessments to obtain the necessary data.
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Are transition age youth subject to order of selection?

Yes, as with all DOR consumer applicants, transition age youth are subject to DOR’s order of selection. If a student/applicant is found eligible for VR services, but cannot be served because of the order of selection, the SVRC should refer the student to other appropriate workforce investment partner agencies.
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Policy states that an IEP must be written prior to a student’s exit or graduation from high school. What should the SVRC do if the student is referred just before graduation?

Federal regulations mandate that an IPE be written prior to graduation for eligible students. If this is not feasible, the reason for the delay should be documented in the case file.
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What should a SVRC do if they believe a student is unrealistic in their career goals?

It is the SVRC’s responsibility to provide accurate information for the student to use in the choice-making process, and to facilitate informed decision-making. Although DOR is not required to financially support unrealistic goals, it may be appropriate to support a work experience or one or two college courses in an area of study that will help the student learn about their capacities and the educational or work requirements of a particular job through direct experience. Based on a student/consumer’s performance in one of these experiences, the SVRC may be able to better assist students in exploring related jobs or career paths that meet the student’s abilities and capabilities as well as have more evidence-based information on which to base future decisions about VR support of the IPE goal.
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What is the SVRC role in post-secondary education in terms of planning and support?

SVRCs should be actively involved in determining the appropriateness of post-secondary education and training and guiding the student through the financial aid process, if applicable. If the student will need support services while in college or training, the SVRC should work with the student to ensure coordinated services are in place. This generally requires the student to contact the financial aid office and/or the Disabled Student Programs and Services office in the post-secondary institution.
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When does DOR become responsible to pay for vocational services?

Prior to graduation or exit from school, DOR is responsible for expenses directly related to the student’s vocational rehabilitation activities, in support of the IPE goal, that are not part of a free and appropriate public education. Examples of these types of vocational rehabilitation services include job development/placement, supported employment services such as job coaching, and transportation to and from job sites. After the student has graduated or exited from school, DOR is responsible for providing vocational services required to meet an IPE goal.
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What are the relative responsibilities of the Local Education Agencies and DOR in respect to providing assistive technology?

The term 'assistive technology device' means any item, piece of equipment, or product system, whether acquired commercially off the shelf, modified, or customized, that is used to increase, maintain, or improve functional capabilities of an individual with a disability. The need for Assistive Technology (AT) should be an integral part of a comprehensive assessment for students with disabilities in all areas related to their disabilities. It is important to use a collaborative school-based team approach in education settings for assessment, planning, and provision of needed AT, which includes individuals who are knowledgeable about the student's disability (ies), needs and strengths in the area of AT. Assistive technology can be a tool for access (e.g., school environment, core curriculum) or for independence (e.g., communication, mobility) and will therefore change as the student's needs change and as technology continues to change. The delivery of accessible technology and/or assistive technology could be required as part of a student’s IEP.  However, a student’s IEP might also be implemented in other ways such as the use of paraprofessional assistance or program modifications rather than the delivery of accessible technology.
The Rehabilitation Act identifies “rehabilitation technology” as mandatory service that is exempt from the determination of the availability of comparable services and benefits. Therefore, DOR has the affirmative responsibility to provide these services for VR clients without determining the availability of alternative funding sources. Nevertheless if an exempted service such as an assistive technology device is known to be readily available from a local education agency at the time the service is needed to accomplish a rehabilitation objective in the individual's IEP it is prudent for the DOR to use those sources in order to conserve VR funds.
DOR and LEAs should work in partnership to ensure that individuals with disabilities receive necessary rehabilitation technology at the time they need a particular service. Greater collaboration between DOR and LEAs in providing rehabilitation technology is essential to ensure that greater numbers of individuals with disabilities, including those with severe disabilities, can achieve high quality employment outcomes.
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When is it appropriate for DOR to purchase assistive technology for transition age youth?

If the assistive technology is not required for the student to participate in educational activities, but will be necessary to accomplish an employment goal that is specified in the IPE, then DOR may purchase the equipment. For example, the school has an assistive listening system for use in the classroom. It does not belong to the student and is used only in the classroom. The hard of hearing student is adequately accommodated in school. However, to participate in a paid work experience, this student will need assistive listening equipment to adequately communicate with the employer and co-workers. If the employment setting is compatible with the IPE outcome, it is appropriate for DOR to purchase the equipment prior to the student’s exit from school.
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Can DOR develop a Supported Employment plan for a student who is still in school?

Yes, it is allowable and appropriate for DOR to provide Supported Employment (SE) services for transition age high school students. SE is a service option for individuals with the most significant disabilities who have a need for continuing support to maintain employment after a VR case is closed. SE provides an opportunity for individuals to work in an integrated community setting and receive customary wages and benefits (or work toward competitive employment).
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When should a Supported Employment eligible student receive services?

The consumer’s needs and circumstances should dictate when services commence. SE services should begin before the student leaves school with the goal to obtain an appropriate, permanent community SE placement upon their exit from high school.
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Can Habilitation Funds for Extended Services be used for DOR Regional Center consumers in high school?

No. The Habilitation Services Program does not provide services to Regional Center consumers until they leave high school. However, a SVRC can provide SE services to in-school youth if there is a reasonable expectation that a source of extended services will be available once the consumer exits school. A copy of the Regional Center’s Individualized Program Plan (IPP) could support a reasonable expectation that the consumer is eligible for Regional Center services and will be referred to the Habilitation Services Program for SE ongoing support services when leaving school.
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Is there a formal agreement between DOR and CDE regarding transition services that can be referenced for future planning purposes?

DOR and CDE have entered into a formal Interagency Agreement (IA) to create coordinated polices, practices and procedures to ensure a seamless delivery of transition services to eligible secondary students with disabilities who meet priority of service under the Order of Selection.
The conditions of the Interagency Agreement apply to all California secondary students with disabilities who are eligible for DOR services.
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