High Quality Employment: What Does it Mean?

When we in the vocational rehabilitation (VR) field say the phrase "high quality employment outcome," what do we mean? How do we define such an elusive and, some might say, subjective concept? How do we know when we have arrived at a point where the quality of an employment outcome is equally as important as the fact that an employment outcome has been achieved? These are the questions I have wrestled with as the Commissioner of the Rehabilitation Services Administration (RSA). RSA has tried, through various means, to address this somewhat thorny issue. Here are some of the steps we have taken and an explanation of why we took them.

Project Employ

In 1998, the President's Committee on Employment of People with Disabilities (President's Committee) approached RSA to request our assistance in producing a series of public education materials. The result was a kit designed to publicize the efforts of some VR agencies, community rehabilitation programs (CRP's) and employers to place individuals with mental retardation in "nontraditional" positions within office environments.

File clerk, data entry specialist and staffer with responsibility for destroying sensitive documents are some of the positions highlighted through "Project Employ." The positions are housed within small, medium, and large companies which offer benefits and competitive salaries to the individuals with disabilities hired into these jobs that traditionally have not been held by those with disabilities. In fact, one of the main criteria for a job to be included as part of "Project Employ" is that the positions offer the same benefit and salary structures as that available to all employees within the company.

RSA has publicized "Project Employ" through its 1998 National Employment Conference and has issued an Informational Memorandum on the topic. It is our hope that other VR agencies will follow the lead of those states already seeking nontraditional, higher quality outcomes for individuals with mental retardation and other disabilities.

The President's Committee has copies of the "Project Employ" kit, including a videotape for use in meeting with employers, available for a nominal fee. The committee can be reached at [phone].

Discretionary Grants

RSA's efforts to fund innovative and effective projects to improve employment outcomes are also part of our overall strategy for enhancing job quality for individuals with disabilities. Through our Projects With Industry (PWI) and Systems-Change grants, among others, we have worked to provide incentives for state VR agencies and other rehabilitation providers to seek employment opportunities for individuals with disabilities that meet or exceed our standard for quality, i.e., employment in the competitive, integrated labor market for which an individual with a disability is compensated and receives the same benefits as any other employee.

Policy Directive (PD) 97-04

PD-97-04 states its chief policy: "The employment goal for an individual with a disability receiving services under the State VR Services Program (authorized by Title I of the Rehabilitation Act) must be based, primarily, on the individual's strengths, resources, priorities, concerns, abilities, and capabilities. The employment goal also must reflect the individual's interests and informed choice to the extent that those factors are consistent with the individual's strengths, resources, priorities, concerns, abilities, and capabilities." The PD also states that labor market conditions in the local area and the cost of providing needed services in order to achieve an outcome could not, on their face, eliminate a goal that was consistent with the strengths, resources, priorities, concerns, abilities, and capabilities of the consumer.

Using PD-97-04 as a guide, it is clear that quality employment outcomes must be determined by taking into account factors in addition to the traditional ones of wages, employment setting, and the mere fact that an employment outcome was achieved. Deference must be granted to the individual's informed choice when the desired employment outcome is consistent with the individual's strengths, resources, priorities, concerns, abilities, and capabilities.

Notice of Proposed Rulemaking on Extended Employment

A stated purpose of the Rehabilitation Act is for all "programs, projects, and activities receiving assistance under the Act [to] be carried out in a manner consistent with the principles of inclusion, integration, and full participation of the individuals" (section 2(c)(3), emphasis added). Furthermore, section 100(a)(3)(B) of the Rehabilitation Act requires the state VR services program to be carried out in a manner consistent with the principle that "[i]ndividuals with disabilities must be provided the opportunities to obtain gainful employment in integrated settings." "Extended employment," by definition, means work in a nonintegrated or sheltered setting, thus making it inconsistent with both the purpose and policy of the Rehabilitation Act.

Our regulatory proposal would rescind our recognition of "extended employment" as a final employment outcome and would establish that "extended employment" will be appropriate only when used as an interim step leading to a final employment outcome in an integrated setting. We are proposing October 1, 2001, the beginning of Fiscal Year 2002, as the effective date for these amendments. This lead time will allow state agencies and others who provide VR services the opportunity to implement these changes in a manner that will be least disruptive to the beneficiaries of the state VR services program (i.e., individuals with disabilities).

In an effort to improve the overall quality of employment outcomes in the VR program, RSA has taken these and other steps. I recognize that our attempts to define "quality" do not capture each and every element that should be present; however, at its core is the idea that quality is measured by the individual and the individual's level of satisfaction with the employment outcome. We are committed to providing the best possible service to our consumers and assisting them in achieving "high quality employment outcomes.

Fredric K. Schroeder

Commissioner Rehabilitation Services Administration