UNITED STATES DEPARTMENT OF EDUCATION

OFFICE OF SPECIAL EDUCATION AND REHABILITATIVE SERVICES

REHABILITATION SERVICES ADMINISTRATION

WASHINGTON, DC 20202

> INFORMATION MEMORANDUM
>
> RSA-IM-01-29
>
> DATE: March 26, 2001

ADDRESSEES: STATE VOCATIONAL REHABILITATION AGENCIES (GENERAL)

> STATE VOCATIONAL REHABILITATION AGENCIES (BLIND)
>
> STATE REHABILITATION COUNCILS
>
> CLIENT ASSISTANCE PROGRAMS
>
> PROTECTION & ADVOCACY OF INDIVIDUAL RIGHTS PROGRAMS
>
> REGIONAL REHABILITATION CONTINUING EDUCATION PROGRAMS
>
> AMERICAN INDIAN VOCATIONAL REHABILITATION SERVICE PROGRAMS
>
> RSA SENIOR MANAGEMENT TEAM

SUBJECT: A Summary of Representative Linkages Between Vocational
Rehabilitation (VR) and Temporary Assistance for Needy Families (TANF)
Programs.

CONTENT: The purpose of this Information Memorandum (IM) is to provide
State VR agencies and their constituencies with a summary of updated
information regarding the ways in which VR and the TANF program can
partner in order to better serve TANF recipients with disabilities. The
document attached to this memorandum was originally issued by the
Rehabilitation Services Administration (RSA) in 1998. It has been
updated periodically since that time.

> The document has two main sections. First, it discusses some of the
> common characteristics of VR/TANF linkages. Second, it provides a
> summary of the activities of various States and tribes to serve more
> effectively TANF recipients with disabilities.
>
> VR agencies that wish to use this document in their discussions with
> other workforce partners should feel free to do so. RSA is working to
> ensure that this or a similar issuance is shared with TANF programs
> nationwide.
>
> The document is not an exhaustive list of States conducting promising
> partnerships between VR and TANF. If you feel that your State's
> efforts should be added to a future version, or if you have any
> questions regarding VR and TANF linkages, please contact Ms. Jenn
> Rigger, RSA's Central Office Employment Specialist, at (202) 260-2179,
> or via email at jenn_rigger@ed.gov.
>
> Mark Shoob
>
> Deputy Commissioner

Attachment

cc: COUNCIL OF STATE ADMINISTRATORS OF VOCATIONAL REHABILITATION

> NATIONAL COUNCIL ON INDEPENDENT LIVING
>
> NATIONAL ASSOCIATION OF PROTECTION AND ADVOCACY SYSTEMS
>
> NATIONAL REHABILITATION FACILITIES COALITION

**Representative Linkages Between Temporary Assistance for Needy
Families (TANF) and the Vocational Rehabilitation (VR) Program**

**[Introduction:]{.underline}**

In the course of implementing welfare reform, considerable attention has
been given to what factors contribute most significantly to long-term
welfare dependency. One factor that appears to have serious implications
for those labeled hardest-to-serve is the presence of disabilities.
Individuals with physical, sensory, mental, cognitive, or emotional
impairments often require support and/or accommodation in order to
succeed in the workplace. For individuals with undiagnosed or hidden
disabilities, or those without access to vocational services and
supports, attempts to enter or remain in the workforce are less likely
to succeed. Current data indicate that between 30 and 40 percent of
welfare recipients have disabilities. This context provides insight into
the types of services that might assist an individual receiving TANF to
move off of benefits and begin working.

For 80 years, a Federal and State partnership has existed to assist
individuals with disabilities to enter or return to the world of work.
The VR program, overseen at the Federal level by the Rehabilitation
Services Administration (RSA) within the Department of Education,
provides services to assist individuals with disabilities in achieving
their vocational goal. The program is funded through a formula grant
with an approximate 20 percent State match requirement. Some of the
services provided to individuals determined eligible could include:
assessment, counseling, vocational training (including on-the-job
training), supported employment, job placement, and rehabilitation
technology services and devices.

Given its long history in providing these types of services to
individuals with disabilities, VR is, in many respects, a valuable asset
to welfare reform efforts on the State and local levels. In fact, many
States around the country have begun to build TANF/VR partnerships.
While it may be too early in some areas to gauge the success of these
partnerships, early evaluations indicate that they are proving
beneficial to the overall success of welfare reform.

There are many ways in which VR and TANF can partner. In an effort to
provide information about some of the types of partnerships that
currently exist, RSA has compiled abstracts from 12 State and Tribal VR
agencies. They were chosen for their representative characteristics and
should not be considered an exhaustive list of States with effective
models of coordination. There are other States and localities doing
excellent work in this area, and RSA will continue to pass along new
information as it is received.

Within some or all of these partnerships, there are several
characteristics that stand out:

-   Organizational Structure of TANF and VR \-- In several examples,
    TANF and VR are located under the same umbrella agency of State
    government. While this does not necessarily dictate a close working
    relationship, it appears to foster cooperation between the two
    entities.

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-   TANF and VR Co-location of Personnel \-- Where co-location of agency
    personnel exists, it seems to stem from local conditions, such as
    involvement in one-stops or similar systems. The co-location appears
    to make referral of TANF recipients who are likely to be eligible
    for VR services easier. Also, co-location has meant a better means
    of addressing the needs of "walk-ins" with disabilities than might
    otherwise exist.

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-   Contracts, Cooperative Agreements, and Protocols \-- In some States,
    the VR agency is unable to serve all eligible individuals with the
    resources available for the VR program. In those instances, an order
    of selection for services, serving first those individuals with the
    most severe disabilities, must be established. Individuals who
    cannot be selected immediately for services are placed on a waiting
    list.

> For those TANF recipients whose disabilities do not meet VR
> eligibility criteria or an order of selection within VR, formal
> agreements seem to be one solution to the problem of how to ensure the
> provision of specialized services. These agreements allow for the
> formal recognition, by both TANF and VR, of the requirements of their
> programs, and the contracts, where they exist, allow the use of TANF
> funds by the VR agency to provide services for which there are
> insufficient VR funds.

-   VR and TANF Requirements \-- One of the biggest obstacles to VR and
    TANF cooperation, according to front-line personnel from both
    entities, is the time limit associated with TANF participation and
    the lack of any such limits in the VR program. A solution that seems
    to be working in some States is an agreement on the part of both
    programs that, once an individual is determined eligible for VR
    services and a vocational plan is written, the execution of that
    plan is considered a fulfillment of an individual's work
    requirement. The average length of time that a VR client receives
    services is two years. Consequently, most TANF recipients receiving
    VR services should complete their VR plan prior to losing TANF
    benefits.

**[Abstracts]{.underline}**

In this section, 12 programs are highlighted. These programs are
examples of effective partnerships between TANF and VR. The information
was gathered from the VR agencies, and several basic questions were
asked of each to develop the summaries. The questions were:

-   Is the relationship mandated by the Governor, State statute, etc. or
    is it more informal?

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-   How do the referrals from TANF to VR occur? Are VR counselors
    co‑located with TANF personnel? Is there a common computer database
    for information‑sharing, etc.?

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-   How do the issues of TANF time limits and VR\'s requirements for
    informed choice, etc. get resolved?

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-   If a TANF recipient with a disability is determined eligible for
    services in a State under an order of selection, is there some kind
    of alternative means of service delivery either through VR or TANF
    or in cooperation to assist that individual to meet TANF work
    requirements?

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-   Your partnership is regarded as successful. Why do you think you
    have achieved the success? What is the single most important factor
    to it?

**Arkansas:**

In Arkansas the relationship between VR and TANF is contractual (VR is
the contractor) and covers the process of referral, evaluation and
possible VR services for TANF recipients. Those TANF recipients who,
based on a disability or medical condition have received a deferral from
the work requirements of Welfare-to-Work, and those recipients applying
for deferrals based on disability or medical condition, are referred to
VR for evaluation and possible services.

The local County TANF case manager is responsible for making referrals
to VR. VR and TANF personnel are not presently co-located. VR counselors
are responsible for visiting TANF offices on an established itinerant
basis. VR and TANF are working to establish an agreed-upon computer
database of information and commonly agreed upon referral, reporting,
and billing criteria.

The language in the contractual agreement addresses such issues as TANF
time limits and VR requirements for informed choice. The language of the
contract states that when a customer has been determined eligible for
rehabilitation services and either refuses to participate or declines to
complete a rehabilitation plan without sufficient reason, a copy of the
case closure documents are to be forwarded to TANF. Such information
substantiates decisions for TANF to impose sanctions. This policy is to
be clearly conveyed to each TANF recipient referral.

At this time, the VR agency is under an order of selection that limits
the agency\'s ability to provide services to clients whose disabilities
are not significant. The TANF contract provides additional resources to
VR that will allow for services to be provided to a significant number
of new clients.

**Colorado:**

Before the TANF law was passed in Colorado, Colorado VR and the Denver
Department of Social Services began to develop a pilot project to help
meet the employment needs of TANF recipients. VR and Denver TANF staff
agreed that a number of clients on TANF were people with disabilities.
Both VR and Denver TANF began discussions to initiate a pilot project to
coordinate efforts.

The VR counselor brings expertise about disability‑related employment
issues and services to the project. The social services caseworker
brings expertise about the TANF program and childcare services to the
project. Through the pilot project, the social services caseworker is
educated about the VR program, and the VR counselor is educated about
TANF. With this information, a TANF caseworker knows which clients to
refer to VR. This simplifies collaboration and coordination among the
TANF caseworker, the VR counselor, and the TANF recipient to ensure
progress toward the same goal. This coordination simplifies sharing
information and coordinating employment goals, avoids duplication, and
allows for special services when necessary.

VR expanded the concept to seven other Colorado counties ‑‑ three are in
the Denver metropolitan area (Adams, Arapahoe and Douglas), El Paso
(includes Colorado Springs), La Plata, Mesa, and Pueblo Counties. Those
TANF agencies contribute 21.3% of the VR counselor\'s salary and almost
all of the diagnostic and training costs for the jointly served clients.
As a result of these projects, it is expected that 290 TANF clients with
disabilities will become employed in 2001, 711 in 2002, and 1,103 during
the third year of the project.

**Connecticut:**

For the past two years, Connecticut's Bureau of Rehabilitation Services
(BRS) has been collaborating with the State's Department of Labor (DOL),
Department of Mental Health, and the Department of Social Services
Division of Family Services. They formed a \"Hard to Serve Committee,\"
the purposes of which are:

1.  To disseminate information and technical assistance to facilitate
    the screening of program applicants with possible learning
    disabilities;

2.  To work with health maintenance organizations that serve Medicaid
    clients with mental illness and/or substance abuse issues; and

3.  To work with each other on referrals/ process and cross training for
    a case management system (which has been contracted by DOL).

**Kansas:**

Kansas is one of the States in which TANF and VR organizationally reside
under the same umbrella agency. There is some co-location of services,
particularly on the local level, and Statewide, there is a strong
knowledge of cross-programmatic requirements. Through the one-stop
systems, some VR and TANF offices share intake and assessment functions.

Kansas has addressed the TANF time limit and its conflict with the more
flexible nature of VR services. The TANF office counts most activities
called for in individuals' written plans with VR as job skills training
for the purposes of meeting the TANF work requirement. That cooperation
and understanding solves one of the more contentious issues facing these
partnerships.

**Maine:**

In the State of Maine, the relationship between VR and TANF is informal.
TANF operates through the Career Centers (One-Stop Centers). VR
counselors are presently co-located in Career Centers throughout Maine.

If a TANF recipient with a disability is already eligible for services,
the VR counselor works with the consumer and the TANF representative,
and the consumer receives services with TANF funds that are contracted
out to rehabilitation service providers who provide intensive services
to consumers. VR does not pay for these services. If the TANF recipient
is not eligible for VR services, there is no VR involvement in the case,
but the individual receives services from the contracted community
rehabilitation providers.

**New Hampshire:**

The relationship in New Hampshire between the VR agency and TANF is an
informal one. The TANF service delivery system is based on an
interagency model that includes staff from Employment Security, and
prior to the implementation of WIA, a staff person from the Job Training
Program. These teams were housed in the local Employment Security
Office. Each VR regional office assigned a specific counselor to receive
referrals and to report back and forth to a counterpart in TANF. The VR
counselor was considered an "ad hoc" member of the interagency team but
was not co-located. Since the implementation of WIA, VR counselors are
located in each of the thirteen one-stop centers on either a full or
part time basis. As liaisons with the TANF team, these counselors accept
referrals, serve these mutual customers or expedite referrals to the
local regional office.

Disagreements that initially occurred were attributed to a mutual lack
of understanding regarding the eligibility and service provisions of
both partner agencies. This has been resolved through joint training and
enhanced communication. Front line staff is encouraged to meet during
plan development and to resolve potential conflicts relative to time
constraints and informed choice. Disagreements that cannot be resolved
with the VR Regional Leader are referred to a designated person in
Central Office who functions as a State liaison and works to resolve
issues with a counterpart in TANF. At VR the State liaison also notes
patterns or trends and will recommend training and strategies to address
these issues.

New Hampshire believes that the partnership is successful because good
communication takes place between the individuals doing the work and a
shared commitment to focus on the needs of mutual customers.

**Oregon:**

VR and TANF reside under the same umbrella State government entity,
facilitating a strong relationship, but one that is more informal than
contracts or other mandates. Referrals are made at the staff level, with
some VR offices co-located with TANF. In addition, VR has out-stationed
staff in the State's Employment Department and other partner offices.
TANF and VR can generate computer lists of mutual clients.

TANF clients who are mutual VR clients with a VR plan are exempted from
the TANF time limits. In addition, Oregon's TANF agency has tapped
private nonprofit contractors (e.g., Goodwill Industries), which have a
history of working with individuals with disabilities. This should
facilitate effective service provision for those individuals with less
severe disabilities who might not be able to receive services under an
order of selection and prevent a "deluge" of VR referrals from TANF.

# Rhode Island:

With both its Office of Rehabilitation Services and Family Independence
(TANF) program under the leadership of the Department of Human Services,
Rhode Island's VR and TANF programs have, through their "Learning
Disabilities Project," committed themselves to a more seamless system of
referral and service provision. The project developed a screening and
assessment tool. Once an assessment of those in the general TANF
population is complete, individuals with learning disabilities are
referred to the project and to VR for application, assessment, and
eligibility determination.

Individuals found VR-eligible then receive learning
disabilities-specific and coordinated vocational evaluation/counseling,
life/social skills training, literacy, and other VR services designed to
meet specific needs of individuals with learning disabilities.
Post-employment services are also part of the project, when needed.
Those TANF recipients determined ineligible for VR return to their TANF
caseworker.

**Utah:**

In Utah, the VR program is administered by the Utah State Office of
Rehabilitation (USOR) and TANF is located in the Department of Workforce
Services (DWS), which also houses other workforce-related services. Even
though the VR and public assistance programs are located in different
government departments, USOR considers the relationship it has with DWS'
programs to be very positive. The VR program has had cooperative
arrangements with Job Services since the late 1970s and working
relationships in the past with other programs providing services to
welfare recipients (food stamps, AFDC, etc.). Under TANF, those prior
arrangements have expanded to encompass a broader scope of TANF-related
programs that are under the DWS umbrella.

Utah's VR, TANF, and other welfare and workforce-related programs use a
common referral form and information technology that allows information
sharing between programs. In addition, the VR program is either
physically located or electronically linked to DWS offices statewide
and, under an RSA grant called "Choose to Work Utah," individualized job
development and placement services are provided to individuals with
disabilities.

USOR has a long history of developing cooperative arrangements with TANF
and other public assistance programs. USOR attributes this experience to
TANF's success in the State.

**Vermont:**

Vermont has always had a cooperative relationship with both the
Department of Employment and Training (DET) and the Division of
Prevention, Assistance, Transition and Health Access (PATH, formally
Division of Social Welfare). This cooperation has led to a pilot
program, funded by Federal Welfare to Work funds, in which VR counselors
are partnered with DET case managers to serve individuals with long-term
welfare dependence. VR provides screening and assessment, disability
accommodations, job site analysis and other vocational supports. The DET
case manager assists with employer contacts and contributes a vast
knowledge of employment services. A job coach provides intensive
community support to both employees and employers.

The pilot program was very successful in identifying hidden disabilities
and providing post-employment supports to keep people working. VR will
now be shifting to a statewide partnership directly with PATH, and
funded by them, to serve individuals who have been medically exempted
from work requirements and who have multiple barriers to employment.
Also, individuals applying for welfare will be screened for a possible
disability and referred to VR for services. Working with VR on an
employment plan counts as a work activity for welfare participants.

Some of the VR counselors are co-located within DET/one-stop centers. VR
counselors will be linked to the PATH computer system and will be
trained as PATH workers, thereby becoming the primary welfare case
manager while the participant is actively working with VR. Referrals
will come directly from PATH.

The success of these partnerships has come from the melding of expertise
and the willingness of all partners to work together to serve the
clientele. VR's experience with the welfare populations suggests that a
large majority of individuals within the welfare system have
disabilities that have not been identified or accommodated. By
addressing the unique needs of welfare constituents and providing
intensive support to overcome barriers, successful transition to work
has been accomplished.

# 

# Washington:

A voluntary relationship between Washington VR and TANF exists; however,
because of the way the two programs are structured within the same
umbrella agency of State government, coordination

is required. A written inter-divisional protocol for referral and
coordination of services has been developed and adopted by the two
agencies. Both agencies have agreed that referrals to VR will be
"managed" to ensure that the agency is not deluged with TANF referrals.

While some VR and TANF offices are co-located on the local and regional
levels, staff believes that this is not necessarily the key element for
success. Instead, the quality of the relationships among key players at
the local level, trust, cooperation, and communication, are most
important. A database is under development that would allow VR and TANF
to identify common clients.

The draft protocol specifies that referral from TANF to VR will be
voluntary, based on the wishes of the client, not a mandate from a case
manager. Once VR eligibility is established, it has been agreed by both
agencies that elements of informed choice shall prevail in development
of a plan of service and that a VR rehabilitation plan shall also serve
as an individual's TANF work plan.

## Native American/Tribal Programs:

For most programs, welfare reform has meant an increase in applications
for service, and for some programs, it necessitated going into an order
of selection in which only persons with the most significant
disabilities can be served. It also necessitated the American Indian
Rehabilitation (AIR) agencies to widen their circle of supports and
first-dollar resources to include services available through TANF,
Native Employment Works, and Welfare-to-Work.

For some programs, welfare reform has allowed coordination of services
in a one-stop office permitting shared services for reception, job
placement, general assistance, cash assistance/welfare, low income
housing energy assistance, low-income food distribution programs, food
stamps, Medicaid, and child care.

For tribes with VR programs, this collaboration may defer the need for
entering into an order of selection status because of the sharing of
support services and resources.

Welfare reform has also challenged the AIR staff to be more vigilant in
their advocacy for persons with disabilities, by providing guidance,
education, and technical assistance to colleagues, since often it is
only the VR counselors and AIR staff that have the knowledge and the
skills to identify and work with persons with disabilities.

**[Conclusion:]{.underline}**

As has been demonstrated by the examples above, there are some
partnerships between TANF and VR that are already in place, and while it
may be, in some States, a little early to evaluate them completely,
early indications are that they are working. Issues such as TANF's time
limits, VR's eligibility requirements, and other programmatic
limitations have presented challenges to the agencies, but some have
found ways to confront them.

Welfare reform is still relatively new, and over time, we anticipate
having more examples of effective partnering to share. We will continue
to disseminate new information as it becomes available. In the interim,
if you would like to discuss any of these partnerships in greater
detail, please contact Jenn Rigger, VR Program Specialist, at
202-260-2179 or via e-mail at jenn_rigger@ed.gov.