### [Comprehensive System of Personnel Development]{.smallcaps}

**[Common Questions and Answers]{.smallcaps}**

**Prepared by**

**The Rehabilitation Training Work Group**

## The Work Group includes

**Rehabilitation Services Administration**

**Council of State Administrators of Vocational Rehabilitation**

**National Council of Rehabilitation Education**

**Commission on Rehabilitation Counselor Certification**

**Council on Rehabilitation Education**

**July, 2000**

Dear Colleague:

Thoughtful observers, contemporary writers and leaders in the field of
vocational rehabilitation have consistently reported that quality
services are provided by qualified personnel. In the Rehabilitation Act
(The Act), the great social planners assured not only the essential
services for overcoming adversity, but also the professional assistance
pivotal in creating careers and building lives.

The information contained in this document will facilitate the full
implementation of the historic Comprehensive System of Personnel
Development (CSPD) provisions of The Act. It is reasonable to expect
that consumers of vocational rehabilitation services will benefit
greatly from their partnership with a qualified counselor and other
rehabilitation professionals.

From various sources over an extended period of time the Rehabilitation
Services Administration (RSA) collected questions and provided answers
to State agencies, universities and providers on the administration of
the CSPD authority. As the body of information grew it became prudent to
establish a nationally recognized panel to review and contribute to the
further development of policy and guidance in this important area of
program administration.

The Rehabilitation Training Group (RTG) was established by the RSA
Commissioner in the winter of 1999 and consists of representatives from
the principal organizations responsible for and contributing to CSPD
implementation. The members represent the Council of State
Administrators of Vocational Rehabilitation (CSAVR), the National
Council on Rehabilitation \"Education (NCRE), the Commission on
Rehabilitation Counselor Certification (CRCC), the Council on
Rehabilitation Education (CORE) and RSA.

We are pleased to send you the first product of the RTG, entitled,
\"Comprehensive System of Personnel Development, Common Questions and
Answers.\" This is the most complete treatment of issues, concerns and
ideas on the subject available to consumers, administrators, educators,
practitioners and researchers

As you assimilate and apply the guidance and advice presented herein,
please share your thoughts and experiences with us. Your input is
crucial to continuous improvement to this vital area of program
administration. The belief that \"Good staff do good things\" is worthy
of pursuit by all individuals who create quality vocational outcomes.

**Rehabilitation Services Administration**

Timothy C. Muzzio, Ph.D.

Ralph N. Pacinelli, Ph.D.

**Council of State Administrators of** **Vocational Rehabilitation**

Peggy Rosser

Ron Vessell

**National Council on Rehabilitation Education**

Donald Dew, Ph.D.

Amos Sales, Ed.D., C.R.C., N.C.C.

**Commission on Rehabilitation Counselor Certification**

Betty Hedgeman, Ph.D.

Susan Gilpin

**Council on Rehabilitation Education**

Jeanne Patterson, Ph.D.

**[Common CSPD Questions]{.smallcaps}**

**A. WHO IS COVERED?**

**What categories of staff must have "CSPD standards?"**

> State agencies must develop standards, consistent with the CSPD
> provisions, for all professional and paraprofessional staff employed
> by the State agency. RSA has established a "minimum" list of
> professions that are considered professional and paraprofessional:
> Rehabilitation Counselors (including supervisors and managers who
> perform any counselor function -- see question X), Vocational
> Evaluators, Job Coaches, Counselor Aides/Assistants Technicians, and
> Job Development/Placement Specialists. We expect State agencies to
> supplement this listing as appropriate to their situation.

**Who does RSA consider to be a "counselor?"**

> RSA's 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 Act states that only a "qualified counselor" can perform certain
functions (e.g., eligibility determination). Does this mean that if a
counselor does not meet CSPD standards they cannot perform these
functions (e.g., cannot perform an eligibility determination)?**

> Yes. Only a qualified counselor that meets the personnel standards
> (consistent with CSPD requirements) can perform those functions.
> However, RSA guidance allows a counselor who does not currently meet
> the standard to perform all counselor functions IF he or she is
> covered under their CSPD plan to be trained to the standard.

**A State VR agency has had a model Transition Unit, with a teacher
having a Masters in Special Education functioning as part of the unit.
This individual, under the supervision of VR staff, serves as a VR
counselor, carrying a caseload and doing all the associated tasks of VR
counselors. She is de facto, a VR counselor. She is also currently under
the agency\'s CSPD plan to obtain additional training in a CORE
accredited program. The question: Can this individual continue to
function as a VR counselor?**

> Yes, so long as she is an employee of the State agency, and provided
> the conditions as described in the response to the question above are
> met. The CSPD provisions apply only to State agency personnel.
> However, remember that only State agency personnel may determine
> eligibility, approve an IPE and determine achievement of employment
> outcomes -- these are functions that the State agency cannot delegate.

**Are supervisors and managers of counselors required to meet at least
the same standard as counselors?**

> The law and regulations do not specify that counselor supervisors and
> managers per se are required to meet counselor standards. However, if
> the supervisor or manager completes any of the counselor functions
> listed above, even for one VR customer, then they must meet the
> standards for counselors

**For those State agencies that operate their own rehabilitation center,
must all the various disciplines working in that center meet their
respective CSPD standards?**

> Yes. The CSPD provisions apply to all employees of the State agency.

**Is an individual who determines eligibility and approves and signs the
IPE for a consumer under the Title VI, Part B Program required to meet
the State standard for vocational rehabilitation counselors or be part
of the State agency\'s plan for current staff to meet the standard?**

> Yes. Any State agency employee who performs any of the functions of a
> counselor at any time must meet the standard for counselors (see
> question x), and the functions described above must be completed by
> the State agency staff -- they are "non-delegable" functions.

**My State agency has a difficult time recruiting specialty counselors
as we have no specialty training programs in our region. We have a
similar problem recruiting counselors of diverse background (disability,
ethnicity). Can we hire such staff below the standard?**

> Possibly. If there is a true barrier to hiring counselors that meet
> State agency needs (including specialty counselors and "diverse"
> counselors) the State agency may hire below the standard provided they
> immediately implement plans to retrain them to the standard. In
> addition, the State must have a plan in place that works toward
> eliminating the need for such "exemptions." States pursuing this
> option must have the full consent and approval of their Regional
> Commissioner.

**How do these provisions apply to contractors that we use to provide
many of our services?**

> The CSPD provisions apply only to State agency personnel. RSA
> encourages State agencies to maintain standards for staff of
> contractors that are consistent with the requirements for State agency
> staff.

**The Act permits an individual eligible for VR services to develop the
IPE without any assistance or to work with anyone, including a qualified
VR counselor employed by the designated State unit, in developing the
IPE. How does this flexibility in the development of the IPE relate to
and complement the provisions of the CSPD that, in most instances,
require designated State unit counselors to have a Master's degree in
order to approve an IPE?**

> The CSPD provisions are designed to ensure that designated State unit
> (DSU) staff, particularly VR counselors, are qualified to carryout
> their responsibilities in assisting individuals with disabilities to
> achieve the employment outcomes to which they aspire. In this context,
> one of the key responsibilities of a DSU counselor is the approval of
> the IPE, regardless of the approach selected by the individual to
> develop the IPE, i.e. the individual develops of the IPE alone, or
> with or without the assistance of the DSU counselor.
>
> Approval of the IPE by the DSU counselor is the gateway to the
> implementation of the IPE. Thus, the DSU counselor must be
> knowledgeable about and conversant with not only a variety of
> disability-related vocational considerations impacting the individual
> but also community resources and agency policies affecting the IPE. To
> make supportable decisions with respect to the appropriateness of the
> provisions of the IPE, irrespective of how it is developed, the DSU
> counselor must make use of the information that is gathered through
> the assessment for determining eligibility and vocational
> rehabilitation needs. (See section 7(2) of the Act for the definition
> of the term \"assessment for determining eligibility and vocational
> rehabilitation needs\")
>
> Since each person\'s needs are unique, the nature, scope, and focus of
> any assessment must be individualized to make supportable
> determinations regarding an eligible individual's chosen employment
> outcome, and the nature and scope of services needed by the individual
> to achieve the selected outcome. To this end, the scope of the
> assessment needs to include information about the individual's unique
> strengths, resources, priorities, concerns, abilities, capabilities,
> interests, and the extent to which the individual\'s choice is
> consistent with these primary employment factors. The assessment,
> while beginning at the time an individual applies for VR services, is
> an ongoing process that can continue after the individual\'s
> eligibility for services has been determined, if needed to develop IPE
> provisions that are realistic and appropriate to the employment needs
> of the individual.
>
> Subsequent to the determination of an individual\'s eligibility for VR
> services, a comprehensive assessment can be carried out, if
> appropriate, to gather additional information upon which an IPE can be
> developed. This assessment can address considerations pertaining to
> the individual\'s personality, interests, interpersonal skills,
> intellectual and functional capacities, personal and social
> adjustment, work experience, vocational aptitudes, personal and social
> adjustments, employment opportunities, medical, psychiatric,
> psychological, and other pertinent vocational, educational, cultural,
> social, recreational, and environmental factors that affect the
> employment and rehabilitation needs of the individual. Information
> gleaned by the comprehensive assessment is key to the development of a
> well-constructed and focused IPE.
>
> Once this assessment has been completed and the nature and scope of
> the IPE provisions have been determined, the individual is ready to
> develop the IPE either with or without assistance from any source. To
> assist the individual to make informed choices with respect to the
> development of an appropriate IPE, the DSU counselor must provide
> pertinent information regarding a variety of IPE considerations such
> as agency financial guidelines and criteria, the mandatory elements
> that must be addressed in the IPE, specific services, community
> service providers, and costs.
>
> Before the IPE can be implemented the DSU counselor must review and
> approve the plan. In making the decision to approve or not approve the
> IPE, the DSU counselor must base the determination on the extent to
> which the provisions of the IPE are congruent with the assessment data
> and agency policies affecting IPE considerations. Subsequent to the
> implementation of the IPE, it is also the responsibility of the DSU
> counselor to ensure that the progress of the individual in achieving
> the provisions of the IPE is satisfactory and, if not, the plan is
> amended with the individual.
>
> The increased flexibility that the Act affords individuals with
> disabilities in terms of greater choice and involvement in developing
> their IPEs does not diminish the role and importance of the work of
> the DSU counselor. It does, however, call for new or enhanced
> competencies on the part of counselors to serve in a variety of
> different roles. For some individuals, the counselor's role will be
> more as a facilitator and coordinator; for other individuals, the
> counselor will serve as an expert source of information; while for
> others, the counselor will need to take a more proactive and
> substantive role in assisting individuals with disabilities in the
> development of their IPEs. Thus, the greater control and empowerment
> provided to individuals in directing their rehabilitation programming
> require DSU counselors to serve in different capacities to complement
> the unique needs and capacities of the individuals with whom they are
> working. To this end, counselor competency is of paramount importance
> and the provisions of the CSPD serve to support the development and
> maintenance of that required competency.

**RETRAINING REQUIREMENTS FOR COUNSELORS**

**If a current State agency rehabilitation counselor does not meet the
standard for a rehabilitation counselor, can they continue to perform
all counselor functions, including approving and signing an IPE and
amendments to it?**

> Such counselors may continue to perform all counselor functions
> provided the counselor is covered under a plan approved by RSA, which
> must include provision for retraining of current staff.

**How long does a State agency have to establish its standard for
rehabilitation counselors?**

> RSA expects all States to have established standards by this time.
> Exceptions can be negotiated under unusual circumstances, with the
> full consent of the RSA Regional Commissioner.

**How long do States have to retrain current counselors?**

> There is no set time line for retraining all counselors. RSA expects a
> timeline that reflects an assertive, yet reasonable plan given the
> particular circumstances of the State. For example, in one State most
> counselors may be at or near the standard. A year or two may be a
> reasonable timeframe for retraining current staff. In another States,
> most counselors may not meet the standard. There may be no in-State
> counselor training program, and the State may be resource poor. Five
> years or more may be a reasonable time frame for such a State. RSA
> depends upon its Regional Commissioners to make this determination.
> The Regional Commissioners are expected to look at the circumstances,
> including number who need to be retrained, capacity of training
> institutions to retrain current staff, and resources available before
> agreeing to a time frame.

**GRANDFATHERING AND COUNSELORS CLOSE TO RETIREMENT:**

**The question of grand fathering continues to come up as it relates to
veteran counselors, many of whom do not meet the standard for
counselors. Can any of them be "grandfathered," exempting them from the
need to be retrained to the standard?**

> No. Grandfathering is not allowed.

**Can rehabilitation counselors who have indicated that retirement is
genuinely planned for 3-5 years continue to function in the strictest
sense as a State agency counselor, even though they are not covered by
the CSPD plan? Is the 3-5 year range from retirement a liberal
interpretation of the CSPD requirement?**

> Every VR customer deserves to be served by a qualified rehabilitation
> counselor. However, RSA understands that State VR agencies face
> challenges in retraining all staff, and that an investment of scarce
> training funds must be targeted toward the most effective use. In this
> regard, RSA has given latitude to States to prioritize who receives
> training. If a State decides to focus on training counselors who are
> likely to be with the agency for many years, and chooses to place
> counselors within, say, five years of retirement at the end of their
> priority list, RSA would likely accept that portion of the plan. Like
> much with the CSPD, decisions must be made consistent with the
> situation and resources of the agency.

**EXPLAINING THE STANDARD FOR COUNSELORS**

**What is the requirement for personnel standards for rehabilitation
professionals as it applies to rehabilitation counselors?**

> State VR agencies must establish personnel standards that are
> consistent with the degree standards of the highest licensing,
> certification or registration requirement in the state, or the degree
> standards of the national certification, CRC. The questions below may
> help clarify what this means and how to apply it.

**We wish to base our standard on CRC. What is the minimum
requirement?**

> If a State chooses to establish its personnel standards for
> rehabilitation counselors upon the national CRC standard, it must, at
> a minimum, require VR counselors to have one of the following (the
> degree requirements referred to are explained in more detail in
> appendix A, "CRC requirements."):

A)  Master's in Rehabilitation Counseling.

> *OR*

B)  Master's degree in counseling with a graduate course in Theories and
    Techniques of Counseling.

> *OR*

C)  Master's degree in any discipline. At least 18 credit hours
    specified as follows:

```{=html}
<!-- -->
```
1.  One graduate course with a primary focus on the Theories and
    Techniques of Counseling.

> *AND*

2.  Three graduate courses, each with a primary focus on one of the
    following areas:

```{=html}
<!-- -->
```
a)  Occupational Information

b)  Job Development and Placement

c)  Medical Aspects of Disabilities

d)  Foundations of Rehabilitation

e)  Psychological Aspects of Disabilities

f)  Personal and Vocational Adjustments

> *AND*

3.  Two graduate courses, each with a primary focus on one of the
    following areas:

```{=html}
<!-- -->
```
a)  Assessment

b)  Research Methodology

c)  Vocational and Career Development

d)  Community Resources

e)  Case Management

f)  Delivery of Rehabilitation Services

```{=html}
<!-- -->
```
D)  A current CRC certificate, regardless of degree

**Our State has chosen the "CRC eligible" as the standard. Not just the
degree, but all that makes one eligible to sit for the CRC exam. What is
the requirement?**

> There are two components -- a qualifying degree, plus internship
> and/or employment requirements. These are explained below:

I.  **[Degree Requirements]{.underline}:**

> Master\'s in Rehabilitation Counseling. Depending on whether the
> degree was granted by a CORE accredited program, a supervised
> internship and/or employment experience are required.
>
> *OR*
>
> Master\'s degree in counseling with a graduate course in the Theories
> and Techniques of Counseling, and 60 months of employment experience
> with 12 of the 60 under the supervision of a CRC. Additional
> coursework in Assessment, Occupational Information or Job Placement,
> Medical or psychological Aspects of Disabilities, or Community
> Resources or Delivery of Rehabilitation Services will lessen the
> amount of required employment experience.
>
> *OR*
>
> Master\'s degree in any discipline plus 18 hours of graduate courses
> as described in the question above along with 36 months of employment
> experience where 12 of the 36 was under the supervision of a CRC.

II. **[Internship/Experience Requirement]{.underline}**

> In addition to the education requirement, there is an internship
> requirement and employment requirement. With a Master\'s in
> Rehabilitation Counseling from a CORE accredited program, a 600-hour
> internship supervised by a CRC is required. If the program was not
> CORE-accredited, 12 months of employment under the supervision of a
> CRC is required in addition to the 600-hour internship supervised by a
> CRC. If the program was not accredited by CORE and there was no
> 600-hour internship supervised by a CRC, then 24 months of employment
> experience with 12 of the 24 under the supervision of a CRC is
> required. With a degree in counseling, employment experiences
> requirements range from 36 to 60 months with 12 under the supervision
> of a CRC, depending on the amount of applicable coursework. With a
> master's degree in any discipline and the required 18 hours of
> coursework, 36 months of employment experience with 12 under the
> supervision of a CRC are required.
>
> More detail on these requirements can be found in appendix A. The
> complete set of requirements for CRC can be viewed and downloaded at
> the following web site:
>
> **http://www.crccertification.org**

**Our State has chosen the "CRC eligible" as the standard. A major
barrier we have found is the supervisory requirement. What are the
options for meeting this requirement? Can it be met on the current job?
Must the supervisor be a CRC?**

> Supervision under a CRC can be the immediate supervisor or anyone
> within the upper chain of command. This can be met on the current job.
> If there is no one in the chain of command to supervise, provisional
> supervision can be arranged.

**The Rehabilitation Act states that State agencies are responsible for,
"the establishment and maintenance of standards that are consistent with
any national or State approved or recognized certification, licensing,
registration, or other comparable requirements that apply to the area in
which such personnel are providing vocational rehabilitation
services..." Does this mean that a State VR agency may choose to
establish its standards for VR counselors on standards such as state
personnel standards?**

> No. The regulations clarify that other comparable requirements
> (including State personnel requirements) may form the basis of
> personnel standards **only** in the absence of State or national
> certification, licensing or registration requirements. Most States
> have certification, licensing or registration requirements, and the
> CRC is a national certification standard.

**If a State establishes a standard based on the CRCC standards and the
CRCC standards are later changed, must the State revise its standard
accordingly? Must rehabilitation counselors who were qualified under the
prior standard become qualified under the new standard?**

> *If a State chooses only the degree requirements of the CRC, then \--*
> A State has some flexibility in this regard. While a State may choose
> to require staff to meet any such "new standard," it could choose a
> different policy. For example, after establishing an initial standard
> (one that is consistent with CSPD requirements), all current employees
> would be required to be retrained to that standard, and "new hires"
> would be expected to meet that standard. If the State or National
> standard changed later, the State would be expected to revise its
> standards, and new counselors would be expected to meet the revised
> standard. Counselors hired before this time would not be expected to
> be retrained to this new standard. Such an approach is similar to the
> CRC practice in which counselors who became certified under a prior
> version of the CRC standards do not have to meet revised degree
> standards.
>
> *If a State chooses the CRC credential as its standard (the credential
> itself, not only the degree requirements), then \--* Once a standard
> is established, it maintains until changed. Those who have met the
> standard, remain certified as long as certification is maintained. The
> state (employer) decides if this is acceptable.
>
> On a related matter, RSA expects States to revise their standards
> within a reasonable timeframe after a relevant licensing,
> certification or registration requirement change. RSA interprets
> "reasonable timeframe" to be one year, under normal circumstances.
>
> CRC includes a category, D-4, which allows persons with Masters
> degrees in any field to be eligible for CRC provided they have
> completed certain coursework. The Matter of Related-Degrees with
> special course work State HRD Specialists believe that although they
> are working hard to get their counselors certified, the closing date
> is unrealistic (it expires in December of 2000).

**Can the deadline be extended?**

> CRCC has extended the phase out date for Category D.4 to December 16,
> 2004. This will allow individuals to apply through December 15, 2004.

**Related degrees.**

> The State HRD Specialist believes there is too much guess work in the
> current process. CRCC should develop a listing of acceptable related
> degrees that qualify and what relevant course work must be
> successfully completed for the CRC.
>
> CRCC generally accepts only counseling degrees. Other degrees are
> reviewed individually for content and comparison to the standards. The
> counseling degrees and D 4 specify the course work.

**What are the options for meeting the supervisory requirement for
individuals employed by state VR agencies? Can it be met on the current
job? Must the supervisor be a CRC?**

> Under ideal circumstances, the counselor\'s immediate supervisor is a
> CRC. Recognizing that this is not always the case, there are a number
> of ways that this requirement can be met:

1.  CRCC has provided for \"provisional supervision.\" See Attachment
    #1. As long as a \"Provisional Contract\" has been approved (i.e.,
    prior approval), a counselor who is certified can provide the
    supervision necessary for a counselor to meet the requirement of
    having been supervised by a CRC. However, to obtain approval, the
    individual must apply for certification and indicate that they will
    require provisional certification.

2.  Supervision is not always the immediate supervisor: For example, if
    the individual in charge of \"Field Services\" for the state VR
    program is a CRC, that person is, in fact, supervising the
    counselors within the state agency. Thus, the supervisor can range
    from one\'s immediate supervisor to the director of the agency.
    However, the person doing the supervising must have responsibility
    for counseling activities. In other words, you cannot have someone
    who is the Chief Financial Officer serving as supervisor.

3.  For individuals who are meeting CSPD requirements through the
    granting of the degree, the counselor can complete the internship on
    the job. (CORE does not prohibit this. Some institutions have not
    allowed it, but it can be negotiated. For example, the job hours
    \[600\] count towards the internship, but the internship may include
    specific objectives to enhance one\'s role, e.g., conducting a
    transition group; working with a couple of clients from someone
    else\'s caseload, if the counselor has a specialty caseload;
    targeting placement, if that has not been a counselor\'s strength.)

**Related Degrees: There seems to be much inconsistency and guesswork on
the part of the agencies. Can CRCC provide greater specificity?**

> CRCC is unable to provide greater specificity. The curriculum of each
> program is reviewed to ensure that all standards are met. The most
> frequent problem is not so much the name of the degree, but that it
> does not include a theories and techniques of counseling course.
> Individuals who believe they have had the \"content\" that would be
> included in a Theories and Techniques of Counseling Course, but the
> course had a different title, should always submit the course
> description and preferably the course syllabi to document that the
> course meets the intent of the requirement. If the content is
> contained in a number of different courses, then all of the relevant
> syllabi should be submitted.

**IMPLEMENTATION: RETRAINING CURRENT STAFF**

**How are we to pay for retraining current staff?**

> The RSA training program has provided \$20,000,000 in funding for the
> retraining effort, and every State agency has access to some training
> "slots" or funds under the current allocation. While RSA long-term
> training grantees are funded primarily to train students to increase
> the supply of counselors available to state agencies, some of these
> grantees provide scholarships to state agency counselors. States are
> also expected to use some of their in-service training dollars for the
> retraining effort. States are also expected to use other additional
> funds, such as Title I funds or State funds to retrain current staff
> within a reasonable time frame. To view a list of RSA-funded CSPD and
> other long term training grants that offer scholarship assistance,
> visit the RSA training program web site at
> www.ed.gov/offices/OSERS/RSA/PGMS/RT.

**The "CSPD" grants funded by RSA are helpful in retraining our current
counselors to the standard. May we use those grants to train "counselor
aides" or others who would make good counselors? May we hire staff below
the standard and use the grant to train them to the standard?**

> The CSPD grants are to train current counselors who do not meet the
> standard in their State, to bring them up to the standard. The grant
> conditions on these CSPD grants are very specific \-- grantees may
> [not]{.underline} use their funds to train any staff but current
> counselors, nor for any purpose but to bring current counselors up to
> the degree standard established for rehabilitation counselors. The
> reason for this is simple. The VR system has 4,000 counselors who need
> to be retrained. The funds available for retraining these counselors
> are limited. To use the few funds available for other purposes
> severely dilutes the effort. We encourage states to train other staff
> members who show potential to be a counselor, but the State should use
> other resources for doing so.

**Concerning the CSPD grants funded by RSA, may we train non-counselor
staff to the standard we have established for the appropriate category
of personnel?**

> No (see response to previous question).

**What happens if an individual cannot pass the GRE or other entrance
requirements of the universities?\"**

> The graduate entrance requirements of the Council on Rehabilitation
> Education (CORE) accredited programs may include the Graduate Records
> Exam (GRE), the Miller's Analogy Test (MAT), and grade point average
> of undergraduate program have been established because they are
> predictors of ability to be successful with graduate studies.
>
> Some institutions may have options of a \"provisional admissions
> status\" which may be considered with scores in one area that are just
> below the cut-off or other entrance requirements that are not met. If
> the entrance requirements cannot be met and no \"provisional
> admissions status\" is possible, the applicant cannot be admitted.
>
> One option for such an applicant may be to enroll in coursework at an
> institution as a non-degree student which would allow individuals to
> complete requirements to become CRC eligible, thus fulfilling CSPD
> requirements.
>
> In addition, some institutions may waive some entrance requirements
> for the adult learner.
>
> Resources for identifying other options include the National Council
> on Rehabilitation Education (NCRE) and the Oklahoma State University
> Clearing House of Rehabilitation Training Materials.
>
> If CRC is the standard for counselors and it is expected that their
> supervisors and managers met the same standard, we have found that
> some managers and supervisors are unable to quality to sit for the
> exam. (This is because they are not providing direct counseling
> services, since they are supervisors).

**Are there plans to change this?**

> There are no plans to change the CRC standard. The Commission has
> always felt that someone in a supervisory capacity should have direct
> counseling experience in his/her past. There have been a few instances
> where this direct counseling occurred so long ago as to make
> verification difficult. In those instances, the Commission has worked
> with the individual to try to secure acceptable verification.

**APPENDIX A**

**SECTION 3: CRITERIA FOR ELIGIBILITY**

CRCC does not discriminate on the basis of race, color, religion,
national origin, sex, age, disability or marital status. To be eligible
to sit for the CRC examination, an applicant must be of good moral
character, reputation, and fitness for the practice of rehabilitation
counseling and must meet **EVERY** requirement in **ONE** of the
categories that follow. **ALL** education and employment requirements
must be fully satisfied by **JANUARY 1** for the **SPRING** cycle or
**JULY 1** for the **FALL** cycle. Those applications that do not meet
the eligibility criteria for **ONE** of the following categories by the
required dates will be automatically denied. Please read the categories
carefully.

**[Category A]{.smallcaps}**

**Degree:** Master's in Rehabilitation Counseling.

**Granted by:** A rehabilitation counselor education program fully
accredited by the Council on Rehabilitation Education (CORE) when the
applicant's degree was granted. If you are unsure of the status of your
school when your degree was granted, contact your university.

**Internship Requirement:** Internship of 600 clock hours supervised by
an on-site CRC or by a faculty member who is a CRC. The internship must
have been in rehabilitation counseling and the intern must have provided
direct rehabilitation counseling services to individuals with
disabilities.

**Employment requirement:** None.

**[Category B]{.smallcaps}**

**Degree:** Master's in Rehabilitation Counseling.

**Granted by:** A rehabilitation counselor education program that was
NOT fully accredited by CORE when the applicant's degree was granted. If
you are unsure of the status of your school when your degree was
granted, contact your university.

**Internship requirement:** Internship of 600 clock hours supervised by
an on-site CRC or by a faculty member who is a CRC. The internship must
have been in rehabilitation counseling and the intern must have provided
direct rehabilitation counseling services to individuals with
disabilities.

**Employment requirement:** Twelve (12) months of acceptable employment
experience (see Section 5) under the supervision of a CRC. If you have
met the employment criteria, but lack supervision of employment by a
CRC, you must complete a **Provisional Contract** (see Section 6).

**[Category C]{.smallcaps}**

**Degree:** Master's in Rehabilitation Counseling.

**Granted by:** A rehabilitation counselor education program that was
NOT fully accredited by CORE when the applicant's degree was granted. If
you are unsure of the status of your school when your degree was
granted, contact your university.

**Internship requirement:** None.

**Employment requirement:** Twenty-four (24) months of acceptable
employment experience (see Section 5) including a minimum of twelve (12)
months under the supervision of a CRC. If you have met the employment
criteria, but lack supervision of employment by a CRC, you must complete
a **Provisional Contract** (see Section 6).

**[Categories D.1, D.2, D.3:]{.smallcaps}**

*To be eligible for certification in these categories, your master's
degree must be in the field of counseling.*

*If your degree is in a counseling discipline other than rehabilitation
counseling, the Standards and Credentials Committee (or one of its
subcommittees) will review your transcript to determine that it reflects
the required courses.*

*One course will be accepted for only one focus area. To ensure an
accurate review, CRCC **REQUIRES** that you send a course description or
syllabus for all applicable coursework.*

*For your education to be considered as acceptable for certification
purposes, the courses shown on your official transcript must cover the
areas indicated in the category requirements that follow.*

***(See Section 4 for course definitions.)***

**[Category D.1]{.smallcaps}**

**Degree:** Master's in Counseling. The graduate transcript must reflect
a minimum of:

1\. **ONE** graduate course with a primary focus on the Theories and
Techniques of Counseling; and

2\. **FOUR** graduate courses, each with a primary focus on one of the
following areas:

a\. **ONE** course on Assessment;

b\. **ONE** course on Occupational Information ***[or]{.underline}***
Job Placement;

c\. **ONE** course on Medical ***[or]{.underline}*** Psychosocial
Aspects of Disabilities;

d\. ONE course on Community Resources or Delivery of Rehabilitation
Services.

**Granted by:** A college or university accredited by a recognized
regional accrediting body at the time the degree was conferred.

**Internship requirement:** None.

**Employment requirement:** Thirty-six (36) months of acceptable
employment experience (see Section 5) including a minimum of twelve (12)
months under the supervision of a CRC. If you have met the employment
criteria, but lack supervision of employment by a CRC, you must complete
a **Provisional Contract** (see Section 6).

**[Category D.2]{.smallcaps}**

**Degree:** Master's in Counseling. The graduate transcript must reflect
a minimum of:

1\. ONE graduate course with a primary focus on the Theories and
Techniques of Counseling; and

2\. TWO graduate courses, each with a primary focus on one of the
following four areas:

a\. Assessment;

b\. Occupational Information or Job Placement;

c\. Medical or Psychosocial Aspects of Disabilities;

d\. Community Resources or Delivery of Rehabilitation Services.

**Granted by:** A college or university accredited by a recognized
regional accrediting body at the time the degree was conferred.

**Internship requirement:** None.

**Employment requirement:** Forty-eight (48) months of acceptable
employment experience (see Section 5) including a minimum of twelve (12)
months under the supervision of a CRC. If you have met the employment
criteria, but lack supervision of employment by a CRC, you must complete
a **Provisional Contract** (see Section 6).

**[Category D.3]{.smallcaps}**

**Degree:** Master's in Counseling. The graduate transcript must reflect
a minimum of:

-   **ONE** graduate course with a primary focus on the Theories and
    Techniques of Counseling.

**Granted by:** A college or university accredited by a recognized
regional accrediting body at the time the degree was conferred.

**Internship requirement:** None.

**Employment requirement:** Sixty (60) months of acceptable employment
experience (see Section 5) including a minimum of twelve (12) months
under the supervision of a CRC. If you have met the employment criteria,
but lack supervision of employment by a CRC, you must complete a
**Provisional Contract** (see Section 6).

**[Category D.4]{.smallcaps}**

(This category will be phased out as of December 16, 2004.)

This category is for individuals who have a master's degree in a
discipline other than counseling. For this degree to be considered a
related degree, in addition to the master's degree, the individual will
be required to document at least 18 credit hours of coursework, at the
master's level or above, in the core areas that follow:

**Degree:** Master's in any discipline. At least 18 credit hours
specified as follows:

1.  **ONE** graduate course with a primary focus on the Theories and
    Techniques of Counseling. (This is a basic requirement for future
    consideration of relatedness of degree.)

***AND***

2.  **Three** graduate courses, each with a primary focus on one of the
    following areas:

```{=html}
<!-- -->
```
a.  Occupational Information

b.  Job Development and Placement

c.  Medical Aspects of Disabilities

d.  Foundations of Rehabilitation

e.  Psychological Aspects of Disabilities

f.  Personal and Vocational Adjustment

***AND***

3.  Two graduate courses, each with a primary focus on **one** of the
    following areas:

```{=html}
<!-- -->
```
a.  Assessment

b.  Research Methodology

c.  Vocational and Career Development

d.  Community Resources

e.  Case Management

f.  Delivery of Rehabilitation Services

**Granted by:** A college or university accredited by a recognized
regional accrediting body at the time the degree was conferred.

**Internship requirement:** None.

**Employment requirement:** Thirty-six (36) months of acceptable
employment experience including a minimum of twelve (12) months under
the supervision of a CRC. If you have met the employment criteria, but
lack supervision of employment by a CRC, you must complete a
**Provisional Contract** (see Section 6).

**[Category G]{.smallcaps}**

This is a special eligibility category open **[only]{.underline}** to
students enrolled in a Master's degree program in Rehabilitation
Counseling that is fully accredited by the Council on Rehabilitation
Education (CORE).

If you graduate prior to January 1 (for the spring cycle) or July 1 (for
the fall cycle), your application will be considered under Category A
(see Page 3).

To be eligible under Category G, a student must:

-   Be enrolled in a Master's degree program in Rehabilitation
    Counseling that is fully accredited by the Council on Rehabilitation
    Education (CORE). CORE has two levels of accreditation: Candidate
    for Accreditation and Full Accreditation. Both levels are acceptable
    to satisfy the CRC educational requirements in the applicable
    categories.

-   Have completed 75% of the course work toward the Master's degree by
    January 1 for the spring cycle or July 1 for the fall cycle in order
    to be considered eligible to sit for the CRC examination for which
    application has been made. You will receive the verification form
    following the preliminary processing of your application.

-   Prior to Graduation: Have completed an internship of 600 clock hours
    supervised by an on-site CRC or by a faculty member who is a CRC.
    The internship must have been in rehabilitation counseling and the
    intern must have provided direct rehabilitation counseling services
    to individuals with disabilities.

-   Graduate within six months of the application deadline date.

Students who apply before the appropriate deadline and who meet all
Category G requirements may sit for the CRC examination on the next
scheduled administration date. **However, the examination results will
be released only when the commission receives an official transcript
indicating that a Master\'s degree in Rehabilitation Counseling has been
granted. This transcript must reflect the successful completion of a
600-hour internship in rehabilitation counseling. Furthermore, the
internship will be verified as part of the application process to ensure
appropriateness.**

**[Category I]{.smallcaps}**

**Degree/Dissertation:** Doctorate with a specific program and a
doctoral dissertation with an emphasis on rehabilitation. The graduate
transcript must reflect a minimum of:

-   **ONE** graduate course with a primary focus on the Theories and
    Techniques of Counseling.

**Internship requirement:** Six hundred (600) hours of internship at the
doctoral level in a rehabilitation setting supervised by a CRC.

***OR***

**Employment requirement:** Twelve (12) months of acceptable employment
experience (see Section 5) under the supervision of a CRC. If you have
met the employment criteria, but lack supervision of employment by a
CRC, you must complete a **Provisional Contract** (see Section 6).

**[Category J]{.smallcaps}**

**Reserved for teachers in a rehabilitation counselor program.**

**Degree:** Doctorate in any discipline. The graduate transcript must
reflect a minimum of:

-   **ONE** graduate course with a primary focus on the Theories and
    Techniques of Counseling.

**Employment requirement:** Thirty-six (36) months of full-time
employment\* in a rehabilitation counselor education program, subsequent
to earning the doctoral degree. This category also requires the
supervision of a student and/or direct clinical work with a population
with disabilities as defined by CRCC.

\* Full-time employment is defined as 8 semesters; 12 quarters; or 3
contractual periods of 12 months.

**[Category K]{.smallcaps}**

This category is reserved exclusively for former CRCs who wish to
restore their certification status. To qualify for this category, you
must meet the following criteria:

**Degree:** Master's degree in any discipline. However, the graduate
transcript must reflect a minimum of:

-   **ONE** graduate course with a primary focus on the Theories and
    Techniques of Counseling.

**Granted by:** A college or university accredited by a recognized
regional accrediting body at the time the degree was conferred.

**Internship requirement:** None.

**Employment requirement:** Since employment has been previously
verified by the commission, candidates in Category K only have to submit
verification of their most recent applicable employment experience in
rehabilitation counseling.\
Upon notification of eligibility, you will be required to achieve a
passing score on the certification examination.

**COURSE DEFINITIONS\
FOR REQUIRED COURSEWORK IN\
CRC CATEGORIES D.1, D.2, D.3, D.4, I, J, & K**

**Theories and Techniques of Counseling**

> Theories and Techniques of Counseling is defined as a course in which
> the primary focus shall include the principal theories and techniques
> of counseling and/or psychotherapies. Further, the course
> description/syllabus must show that a majority of the following
> theories were covered and their practical applications discussed:

a)  client centered;

b)  rational-emotive;

c)  Gestalt;

d)  Adlerian;

e)  reality;

f)  psychoanalytic;

g)  behavioral; and

h)  cognitive.

**Assessment**

> Assessment is defined as a course in which the primary focus shall
> include coursework on individual appraisal and standardized testing,
> and provide an orientation to test and measurement principles such as
> norms, reliability, and validity. The content of the course must
> encompass the use of standard tests in areas that include achievement,
> aptitude, interests, personality, situational testing, behavior
> observation, and commercial work samples. Further, the course
> description/syllabus must reflect instruction in the application and
> interpretation of assessment data.

**Occupational Information**

> Occupational Information is defined as a course in which the primary
> focus shall include career education, career development, and career
> exploration. Further, the course description/syllabus must reflect
> coverage of the following: career development theories (e.g., Holland,
> Super, Roe, Minnesota Theory of Work Adjustment, etc.); and the use of
> occupational information and labor market trends in career counseling.

**Job Placement**

Job Placement is defined as a course in which the primary focus shall
include theories of career development and work adjustment; placement
strategies; placement of personnel; special populations; and employer
considerations.

**Medical Aspects of Disability**

Medical Aspects of Disability is defined as a course in which the
primary focus shall include medical aspects of disabilities, medical
terminology, and functional implications of the disabling condition.

**Psychosocial Aspects of Disability**

Psychosocial Aspects of Disability is defined as a course in which the
primary focus shall include the psychosocial impact of a disability on
the individual with the disability, family members, other individuals,
and society.

**Community Resources**

Community Resources is defined as a course in which the primary focus
shall address the educational and vocational programs in a community
that are offered in diverse settings to a variety of populations with
disabilities. Further, the course description/syllabus must reflect
methods of acquiring information and materials regarding resources
available to populations with disabilities.

**Delivery of Rehabilitation Services**

> Delivery of Rehabilitation Services is defined as a course in which
> the primary focus is on delivery systems that encompass public,
> private for-profit, and private not-for-profit settings as well as
> laws and ethical standards affecting counseling practices with
> examples of their application.

**Foundations of Rehabilitation**

> Foundations of Rehabilitation is defined as a course in which the
> primary focus includes course work on the history and philosophy of
> rehabilitation and rehabilitation counseling, noting federal
> legislation concerning vocational rehabilitation and independent
> living mandates. The course also focuses on attitudinal, physical and
> systems barriers to social integration, including the current range of
> services provided for persons with disabilities. Further, the
> rehabilitation process provided in various settings is explored noting
> career alternatives for rehabilitation counselors.

**Personal and Vocational Adjustment**

> Personal and Vocational Adjustment is defined as a course in which the
> primary focus deals with issues and counseling strategies for
> adjustment to disability, and counseling techniques as pertinent to
> people with disabilities with a strong focus on vocational adjustment.
> The course also includes topics of work adjustment, work hardening,
> and job seeking skills.

**Research Methodology**

> Research Methodology is defined as a course in which the primary focus
> is placed on the understanding and application of basic steps in
> planning and conducting quantitative and qualitative scientific
> research. The course covers research concepts and principles including
> descriptive, quasi-experimental and experimental designs, issues in
> data collection, measurement, analysis and interpretation of data.

**Vocational and Career Development**

> Vocational and Career Development is defined as a course in which the
> primary focus deals with job placement issues of work incentives and
> disincentives, theoretical orientation, development and utilization of
> work samples, situational assessment procedures, analysis of work
> relevant data for hypothesis testing and communicating significant
> vocational data. The course addresses various theoretical approaches
> to vocational planning and the impact of theory on practice. This
> course also covers career development theories, theoretical
> orientation and job placement strategies and techniques that
> facilitate employment of people with disabilities.

**Case Management**

> Case Management is defined as a course in which the primary focus is
> on the dynamics of managing a client caseload, conducting intake
> interviews, establishing community resources, gathering and
> interpreting medical, vocational, social, educational and
> psychological information and report writing. Further, the course
> addresses case management practiced in industry, public and private
> practice settings as well as knowledge of the managed care system and
> consulting with other rehabilitation professionals.