The rehabilitation field has flexed and is embracing the new workforce development initiatives on the federal level, while keeping our focus on the best interests of the individuals with disabilities whom will be most affected by these new programs. There is total unanimity among our membership that each person should have the opportunity to reach the highest, most independent and integrated level of vocational achievement possible. Our concern is that the NPRM would effectively remove a vocational option from the existing continuum. This is an option that continues to represent, a necessary step, for many, toward eventual community employment. RSA needs to fully evaluate the impact of the proposed rulemaking on people with the most severe disabilities before enacting such a rule.
Vocational rehabilitation is an interactive process and is ultimately defined by the individual.
It assists people with disabilities to reach their own personal best. No matter the form the vocational rehabilitation system takes, success in employment requires a good job match. The practical effect of the proposed change in regulation would not be more people with disabilities in community based employment. The proposed change would create regulations denying entry into the VR system, for people who may not appear to be able to reach that outcome at the end of their VR sponsorship. In New York State we are concerned that process and ethics are at odds.