The agreement to streamline the public vocational rehabilitation process.

The agreement between the Rehabilitation Services Administration (RSA) and the Council of State Administrators of Vocational Rehabilitation (CSAVR) to streamline the public vocational rehabilitation service delivery system grew out of a CSAVR initiative following the reauthorization of the Rehabilitation Act in 1992.

Preparing for the reauthorization, a major task force of the council reviewed all known criticisms of public vocational rehabilitation in order to ascertain which "shortcomings" could be alleviated or corrected by the Congress in amending the Rehabilitation Act.

What the task force found was that the vast majority of criticisms were not of the Act or the statute, but rather were leveled at the public service delivery system, little of which is provided for in the statute. The vast majority of concerns were facets of the delivery system which were the result of years of practice, state and federally-imposed requirements, auditing safeguards, and others.

This exercise made it plain to CSAVR hat the service delivery system, which had been in existence for more than 76 years, had become a major impediment and an onerous obstacle to the central purpose of the statute--to train and place in competitive employment eligible persons with disabilities.

Determined to remedy this troubling situation, the council convened a 3-day retreat in 1993 at the Aspen Institute for Humanistic Studies on the Eastern Shore of Maryland. The conferees, which included state administrators, RSA representatives, rehabilitation educators, and lawyers, were given the charge of taking the delivery system totally apart and building it back, piece by piece, into a streamlined system which would facilitate outcomes, while being both customer-friendly and--equally important--user-friendly. As a result of this meeting many of the state agencies have implemented streamlining initiatives.

The council agreed upon a set of principles designed to increase the numbers of people with disabilities going to work. At the same time, an equally important integral goal was improving the timeliness and quality of service and the nature and quality of jobs obtained by the customers served by the public program.

The resulting document, Recommendations for a Model Service Delivery System for Public Vocational Rehabilitation, outlined four steps in the delivery of vocational rehabilitation (VR) services: (1) Eligibility Determination, (2) Vocational Planning, (3) Provision of Employment Services, and (4) Job Placement.

The conferees concurred that the case review and reporting structures should enhance and support these four steps. It was also noted that the status system has become a basic part of the VR process but actually does not exist in law and is therefore a creature of regulation, policy, and/or practice. Hence, the status structure could be changed to meet the contemporary demands of a more responsive service delivery system.

It became clear that, in order to fully implement the intent of the streamlining initiative, CSAVR, its member state agencies, and RSA needed to agree on some fundamental changes in policy and practice. Two of the most significant changes were in the areas of case review and reporting. The first affects counselor practice in all of the 50 states, and the latter has reinforced the rigid status structure that has served to impede the provision of timely and effective services.

To fully understand the implementation of the streamlining agenda, it will be useful to review the actual agreement.

The first statement relates to its purpose:

In order that the public vocational rehabilitation program will assist more eligible people with disabilities to obtain real jobs at real wages.

The supporting vision is further stated:

The future of the Public Vocational Rehabilitation Service Delivery System is dependent, in part, upon streamlining the Public Vocational Rehabilitation Service Delivery System to work in partnership with consumers to achieve meaningful employment outcomes. The primary focus of this effort must be the achievement of gainful employment outcomes in integrated settings rather than a focus on process.

The agreement goes on to say:

Over the past 2 years, The Rehabilitation Services Administration (RSA) has assisted these State Agencies in carrying out streamlining activities. These streamlining efforts sought to identify practices and policies impeding the rehabilitation process and outcomes from the perspective of consumers, advocates, and rehabilitation professionals.

Recognizing the need to simplify "process" requirements throughout the nation's Public Vocational Rehabilitation System, the RSA in collaboration with the CSAVR commits to a national effort designed to facilitate consumer-responsive, high quality efficient Public Vocational Rehabilitation outcomes. Many of the "process" requirements generally considered to be impediments to an efficient, responsive system have evolved over time and have become institutionalized in the Service Delivery System. To facilitate an effective National Streamlining Initiative, State Vocational Rehabilitation Agencies will be asked to undertake a review of current Agency practices and processes. The Rehabilitation Services Administration will provide Technical Assistance and resources to assist State Vocational Rehabilitation Agencies in these streamlining efforts. Additionally, the RSA commits to ensuring that Federal Regulation and Policies to minimize "process" requirements and support a clear focus on quality employment outcomes.

Further, the RSA commits to incorporate this philosophy into its monitoring practices. Comprehensive Monitoring will focus on areas of concern identified by consumers in individual states.

The RSA and CSAVR Streamlining Initiative represents a joint commitment to ensuring a clear focus on quality employment outcomes for people with disabilities.

The success of the Streamlining Initiative is rooted in a philosophy of a consumer-driven, outcome-based system of Public Vocational Rehabilitation.

Moreover, the scope of the agreement was defined:

Each of the steps to implement the above Vision has specific Actions associated with them and dates by which they are to be accomplished.

The CSAVR and RSA commit their respective resources to the accomplishment of these Strategies and Actions within the time deadlines agreed upon. These actions and time frames recognize the opportunity at hand and the significance of timely implementation.

It is also important to recognize that the CSAVR and Member State Vocational Rehabilitation Agencies are prepared to assist, through the availability of State Vocational Rehabilitation staff, in the work on specific action steps.

This streamlining effort is a joint effort between the RSA and the CSAVR which will require appropriate and available Federal and State staff time and expertise.

The RSA and CSAVR will encourage all State Rehabilitation Agencies to review the plan with their Rehabilitation Advisory Councils, and other stakeholders, to seek their involvement in, and support of, this plan and its implementation in the State Agencies.

It was further agreed that a very specific workplan was needed to bring the streamline agenda to life. The specific objectives and action steps were:

1. Promote State Vocational Rehabilitation Agency self-evaluations in order to identify and promote the adoption and use of policies and procedures that result in a Streamlined Service Delivery System focused on "employment outcomes."

ACTION: The CSAVR will notify all member state vocational rehabilitation agencies of this agreement and recommend this as an opportunity for each agency to further streamline its service delivery with the support and technical assistance of RSA and with the involvement of stakeholders in the review for its planning and implementation.

ACTION: RSA staff will provide support and technical assistance to state vocational rehabilitation agencies for the purpose of streamlining the vocational rehabilitation service delivery process in each state agency.

ACTION: The state rehabilitation directors will develop regional support networks, facilitated by each CSAVR regional representative, to work collaboratively in support of the region's individual and collective State Streamlining Initiatives.

ACTION: RSA recognizes that state agencies may, as appropriate, implement this Streamlining Plan utilizing resources from the 1.5 percent set-aside which is required for uses described in Section 123 "Innovation and Expansion" of the Rehabilitation Act.

2. Commit personnel and discretionary resources, including the Regional Rehabilitation Continuing Education Program (RRCEP) and In-Service Training, to achieve the Streamlining Objectives.

ACTION: The RRCEP's will be directed to provide training and technical assistance to state vocational rehabilitation agency staff that are tailored to the needs of the region and the state which adopt the streamlining agenda.

3. Focus on the important steps in the vocational rehabilitation service delivery process: Eligibility, Employment Planning, Service Implementation, and "Employment Outcome."

ACTION: The RSA Commissioner will issue a clear and concise Policy Statement on streamlining to RSA staff and State vocational rehabilitation agencies, defining the new Four-Step System and requiring its use. RSA will provide adequate lead time for state vocational rehabilitation agencies to implement changes in reporting requirements in a consistent, uniform and accurate manner. The Policy Statement will be written to support caseload management and the new Streamlining Initiative.

ACTION: CSAVR will work with RSA to establish the Priority of Issues to be addressed under Policy Streamlining.

4. Utilize the recommendations of the "RSA-CSAVR Section 140 Work Group", when relevant and appropriate, to establish a Statistical and Fiscal Reporting System that supports an employment outcomes-oriented service delivery system and the RSA/CSAVR Streamlining Initiative.

ACTION: Revise the RSA-113 Cumulative Caseload Report, (PD-95-03).

ACTION: CSAVR will share the Streamlining Strategies with the CSAVR members of the "Section 140 Work Group" and request them to develop a work plan and to recommend and develop proposed report changes and instructions, in order to address the goals of the Streamlining Initiative.

5. Maintain and utilize the collaborative State-Federal Vocational Rehabilitation Monitoring System, including the Case Review Instrument, to assure compliance with the law and consistency with the RSA-CSAVR Streamlining Initiative.

ACTION: Adopt the new Monitoring System.

ACTION: Adopt the new Case Review System focused on employment outcomes.

ACTION: Train reviewers in the utilization of the Monitoring System and the Case Review Instrument in order to reflect the new Streamlining Initiative.

ACTION: The CSAVR/RSA Task Force on Monitoring and Case Review will review the RSA Monitoring System and make recommendations from the states' perspective that will enhance and support the Streamlining Initiative.

ACTION: CSAVR's comments in response to the Vocational Rehabilitation Notice of Proposed Rulemaking (NPRM) will include a proposed definition of "substantial services" with supporting rationale.

6. Assure that the RSA State Plan Requirements and Policy Directives are consistent with the RSA/CSAVR Streamlining Initiative and reflect on outcomes.

ACTION: RSA will take steps to assure that State Plan Requirements and Policy Directives developed are consistent with the law, regulations and the Streamlining Initiative.

ACTION: CSAVR will develop model eligibility and Individualized Written Rehabilitation Program (IWRP) forms which reflect the new Streamlining Initiative and the experiences of states which have implemented streamlining.

7. Utilize the Institute on Rehabilitation Issues (IRI) and other effective approaches as vehicles for the continuous refinement and enhancement of improved employment outcomes through the state-federal vocational rehabilitation program.

ACTION: RSA and CSAVR will identify and communicate proposed streamlining issues to the IRI for study and development of useful guidance and training materials in order to sustain, expand, and improve the Streamlining Initiative.

Conclusion

In reviewing the entire effort to streamline the vocational rehabilitation process, the agreement between CSAVR and RSA proved to be an important tool for communicating the overall purpose. Specific individual objectives themselves assured that the necessary underpinnings to the agreement were in fact in place.

It is a compliment to the Council of State Administrators of Vocational Rehabilitation, the individual directors in each state, and to the Rehabilitation Services Administration and its commissioner that this overall improvement of public vocational rehabilitation occurred. There is no other state vocational program of any type that has seen the joining of federal/state officials for the purpose of improving the service delivery process. It is a compliment to all of the parties involved that such an initiative was conceived and implemented in such a timely fashion over the period of just a few years.

Mr. Bartels is Commissioner of the Massachusetts Rehabilitation Commission.