**The Comprehensive System of Personnel Development**

**A Practical Guide**

According to statute and regulations, the State must develop a CSPD).
This system is intended to ensure an adequate supply of
[qualified]{.underline} rehabilitation personnel. State VR agencies must
submit and update the CSPD attachment. Each attachment must include
information on the following topics:

-   **Data System** on Personnel and Personnel Development

-   Plans for **Recruitment and Retention** of Qualified staff

-   **Personnel Standards** to Assure Personnel are Adequately Prepared
    and Trained

-   **Staff Development Plan**

-   Personnel to Address **Individual Communication Needs**

-   **Performance Evaluation System**

-   **Coordination of the CSPD** with IDEA and Inservice Training

-   Opportunity for **Review of Plan by SRC**

The details of each section are presented below. At the end of this
appendix is a "CSPD Checklist" that summarizes the information that
should be in a CSPD attachment.

**DATA SYSTEM**:

The CSPD requires that State units maintain a data system on personnel
needs and resources. Specifically, the data system must include:

-   Personnel Data and Projections

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-   number of personnel in relation to number of clients served

-   number of staff currently needed to meet customer need

-   a five year projection of personnel needs

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-   Personnel Sources

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-   a list of higher education programs that train rehabilitation
    personnel

-   the number of students enrolled in and the number graduating during
    the prior year from those programs by type of program

At a minimum, the State CSPD attachment must describe the development
and maintenance of such a system. RSA encourages State VR agencies to
include a summary of the data to assist in national planning efforts.

**RECRUITMENT AND RETENTION:**

The CSPD also requires that state units have plans for recruitment and
retention of qualified staff to address personnel needs. Specifically
the plan must include coordination with:

-   Institutions of Higher Education

-   Professional Associations

These plans must include special efforts to recruit, prepare and retain:

-   personnel from minority backgrounds

-   individuals with disabilities

The State CSPD attachment must describe such plans.

**PERSONNEL STANDARDS:**

State Units must establish personnel standards that assure personnel are
adequately prepared and trained. The standards must be consistent the
highest entry‑level academic degree needed for any national or
State‑approved or ‑recognized certification, licensing, or registration
specific to a profession. For rehabilitation counselors, this means that
if State approved or recognized certification, licensing or registration
requirements [do]{.underline} exist within the State (such as licensing
standards for rehabilitation counselors in the private sector or in
other State agencies), then the State VR agency must base its personnel
standards for counselors on one of the following:

-   the highest entry‑level degree needed under the existing State
    requirements;

-   a degree that exceeds the degree needed under the existing State
    requirements; or

-   the degree required for the national CRC requirement ‑‑ a master's
    degree in rehabilitation counseling or another masters degree that
    meets CRC specifications (see the CRC criteria at the end of this
    document).

If there are no State‑approved or ‑recognized certification, licensing
or registration requirements for rehabilitation counselors, the State VR
agency must base its personnel standards for counselors on:

-   the degree needed to meet the national CRC requirements ‑‑ a
    master's degree in rehabilitation counseling or another master's
    degree that meets CRC specifications (see the CRC criteria at the
    end of this document); or

-   new State certification, licensing or registration requirements for
    rehabilitation counselors developed by the appropriate
    certification, licensing, or registration body of the State.

**[New personnel]{.underline}:**

RSA expects new personnel hired by the State to meet the standard.
However, if there are reasons why a State cannot hire at that level,
they must present an acceptable justification, establish a baseline
standard for such hires and develop plans that swiftly move such hires
to the standard. States must also establish a strategy to move them to a
position in which they would no longer need to hire below the standard.

**[Existing personnel]{.underline}:**

RSA expects existing personnel to be retrained to the standard. Staff
members who do not meet the standard must be under an approved state
plan to achieve the standard.

While the statute requires standards for all professional and
paraprofessional staff, RSA is focusing initial efforts on
Rehabilitation Counselors. It is important to note that RSA's current
position on who is considered to be a rehabilitation counselor is anyone
who does [one or more]{.underline} of the following:

-   Makes an eligibility determination

-   Approves an IPE and any amendments to the IPE

-   Makes the determination as to who is an individual with a
    significant disability

-   Makes the determination as to who is an individual with a most
    significant disability

-   Makes the determination, in consultation with the individual, of
    ineligibility

-   Makes the determination, in consultation with the individual, that
    the record of service of an individual who has achieved an
    employment outcome can be closed

The CSPD attachment must include the following:

-   a statement of personnel standards for counselors that are based on
    the highest requirements in the State applicable to the particular
    profession, i.e., the highest entry-level academic degree needed for
    any national or State-approved or State-recognized certification,
    licensing, registration, or other comparable requirements

-   an analysis of the extent to which its counselors do not meet the
    highest requirements in the State

-   an identification and analysis of factors (such as shortages of
    qualified personnel, low pay scales, etc.) that may inhibit its
    ability to hire qualified staff

-   short‑term and long‑term strategies for addressing these factors

-   objectives and activities for getting all of its counselors to the
    level of the standard that moves the State effectively toward
    compliance with the CSPD requirements and will result in counselors
    meeting the necessary standard in a timely fashion

-   a commitment of funds to support the CSPD plan

-   an evaluation mechanism to determine whether the CSPD plan\'s
    objectives are being met

-   evidence that the CSPD plan is encourages retraining and hiring of
    staff from minority backgrounds and staff with disabilities

**STAFF DEVELOPMENT:**

State units must develop plans for staff development to assure that
existing staff receives adequate and ongoing training. The plan must be
based on an assessment of the needs of the state unit, and must address
the issues of retention of qualified staff, succession planning and
leadership development and capacity building.

The CSPD places particular emphasis on staff training in the following
areas:

-   Assistive Technology

-   Current Research

-   1998 Amendments to the Rehabilitation Act

-   Workforce Investment Act

-   Informed choice

-   Culturally diverse populations

The State CSPD attachment must describe its system of staff development.

**INDIVIDUAL COMMUNICATION NEEDS:**

State Units must hire and retain staff trained to communicate with
diverse populations, or obtain the services necessary to do so. This
includes communication in the following:

-   Native languages

-   Sign language and other alternative modes of communication

The CSPD attachment must describe its efforts in this area.

**PERFORMANCE EVALUATION SYSTEM:**

The State must describe how the system for evaluating the performance of
rehabilitation personnel in no way impedes the accomplishment of the
purpose of the program.

**COORDINATION OF THE CSPD:**

The law requires coordination among the CSPD, the State's inservice
training program and IDEA. IDEA also requires coordination of the IDEA
CSPD with the CSPD of State VR agencies. The CSPD attachment must
describe its efforts in this area.

**REVIEW OF PLAN BY SRC:**

Finally, the Act requires that the State Rehabilitation Council (SRC)
have the opportunity to review and comment upon the State's CSPD. The
State's CSPD attachment indicates that the SRC has been provided this
opportunity.

The attached "CSPD Checklist" may help State agencies develop their
CSPD. Technical assistance is available through the RSA regional
offices.

**Comprehensive System of Personnel Development (CSPD)**

**Requirements Checklist for CSPD Plans**

(***NOTE***: "\*" indicates items not required, but requested by RSA for
informational and planning purposes)

**DATA SYSTEM:**

Yes No Does the attachment provide evidence that the State agency
maintains a system to collect and analyze on an annual basis data on
qualified personnel needs and personnel development, and does the system
including the type of information below?

\*Does the attachment identify the actual number of designated State
unit personnel with respect to:

> Yes No - type of position
>
> Yes No - ratio of personnel to clients served
>
> Yes No - current staffing requirements to meet the needs of the
> agency's customers (RSA encourages inclusion of the actual number of
> counselors needed).
>
> Yes No - projected requirements to meet the staffing needs of the
> agency's customers for the next five years (RSA encourages inclusion
> of the actual number of counselors needed).

\*Does the attachment identify:

> Yes No - Institutions of higher education that train rehabilitation
> personnel?
>
> Yes No - number of students graduating from those institutions by
> type of program? (RSA encourages the inclusion of the actual number of
> counselors graduating).

**RECRUITMENT AND RETENTION**

Yes No Does the attachment present a plan to address the current and
projected needs for qualified personnel, including the coordination and
facilitation of efforts with institutions of higher education and
professional associations, to recruit, prepare and retain qualified
personnel, including personnel from minority backgrounds and personnel
who are individuals with disabilities.

Yes No Does the attachment describe a plan to recruit and retain
qualified staff?

> Does this plan include efforts to recruit, prepare and retain
> personnel:
>
> Yes No - from minority backgrounds
>
> Yes No - who are individuals with disabilities

**PERSONNEL STANDARDS**

Yes No Does the attachment provide evidence of establishment and
maintenance of personnel standards meeting the requirements of 34 CFR
361.18(c) to ensure that professional and paraprofessional personnel
needed within the designated State unit to carry out the vocational
rehabilitation program are appropriately and adequately prepared and
trained?

Yes No Are the academic degree standards for vocational rehabilitation
counselors and other professionals employed by the designated State unit
clearly identified?

Yes No Are the academic degree standards, particularly for vocational
rehabilitation counselors, based on the highest requirements in the
State applicable to the particular profession, i.e., the highest
entry-level academic degree needed for any national or State-approved or
State-recognized certification, licensing, registration, or other
comparable requirements?

Does the attachment include the following:

> Yes No - The number of staff, particularly vocational rehabilitation
> counselors, who either meet or do not meet the highest requirements in
> the State applicable to the particular profession?
>
> Yes No - Factors, such as pay scales or qualified personnel
> shortages, that adversely affect the ability to hire qualified staff,
> and a strategy to address such barriers?
>
> Yes No - Short-term and long-term strategies including activities,
> objectives and time lines to assist personnel, particularly vocational
> rehabilitation counselors, to meet the required standards in a
> reasonably timely manner?
>
> Yes No - Funding support for the implementation of a retraining plan
> to assist personnel, particularly vocational rehabilitation
> counselors, to meet the highest requirements in the State applicable
> to a particular profession (RSA encourages inclusion of the amount and
> source of such funds)?
>
> Yes No - An evaluation strategy for the planned recruitment and
> retraining efforts to ensure that all personnel, particularly
> vocational rehabilitation counselors, meet the highest requirements in
> the State applicable to a particular profession?

**STAFF DEVELOPMENT**

Yes No Does the attachment include a systematic plan for providing
adequate and ongoing training to all staff?

> Does the plan address the following areas?
>
> Yes No - retention of qualified personnel
>
> Yes No - succession planning
>
> Yes No - leadership development and capacity building

Yes No Is there an indication that the staff development plan was this
based on a needs assessment?

Does the staff development plan indicate training in any of the
following areas (the regulations [emphasize]{.underline} but do not
require these areas)?

> Yes No - Assistive Technology
>
> Yes No - Current Research
>
> Yes No - The 1998 Amendments to the Rehabilitation Act
>
> Yes No - The Workforce Investment Act
>
> Yes No - Informed Choice
>
> Yes No - Culturally diverse populations

**COMMUNICATION WITH DIVERSE POPULATIONS**

Does the attachment address the availability of staff or obtaining
services necessary to communicate with clients;

> Yes No - in their native language
>
> Yes No - In sign language?

**PERFORMANCE EVALUATION SYSTEM:**

Yes No Does the State must describe a system for evaluating the
performance of rehabilitation personnel that in no way impedes the
accomplishment of the purpose of the program?

**COORDINATION OF THE CSPD and INSERVICE TRAINING**

Yes No Does the attachment indicate coordination with the CSPD under
IDEA?

Yes No Does the plan directly link the inservice training grant of the
state agency, and inservice training funds with the various components
of the CSPD?

**STATE REHABILITATION COUNCIL**

Yes No Does the attachment indicate that the state rehabilitation
council has had an opportunity to review and comment upon the
development of the attachment and related policies and procedures?