RSA-911 Reporting Requirements and Pre-Employment Transition Services

Case Service Report (RSA-911) RSA-PD-19-03 Program Year 2020 Implementation WINTAC/RSA Training Series (3/8)

Training Series Objectives 1. Explain the intent of PD-19-03 reporting requirements. 2. Assist State Vocational Rehabilitation (VR) agencies in the implementation of the Case Service Report (RSA-911). 3. When possible, share examples of what needs to live outside of RSA-911 reporting, in addition to the discussed data elements (e.g., source documentation). 4. Provide considerations and expectations during each training (e.g., policies State VR agencies need to establish and implement, available tools and resources, and internal controls). 2

Presenters Rimal Desai, RSA Rachel Anderson, WINTAC 3

Pre-Employment Transition Services (3/8 Training Series) November 2019

Todays Training 1. Reporting Reportable Individuals and Participants 2. Changes from PD 16-04 to PD 19-03 3. Quarterly Reporting Requirements Potentially Eligible Students with Disabilities Students with Disabilities who are Participants receiving Pre-Employment Transition Services under an Individualized Plan for Employment (IPE) 4. Outline for upcoming RSA-911 training topics 5. Tools/resources 5

Pre-Employment Transition Services The Why Behind RSA-911 Changes

Reportable Individuals Students with disabilities, who receive pre-employment transition services prior to applying and being determined eligible for VR services and receiving services under an IPE, are considered Reportable Individuals. These students do not meet the definition of a Participant. Required Data Elements: Data Element Changes in PD-19-03 Name 5 Yes Unique Identifier 6 No Social Security Number (if available) 8 No Date of Birth 10-14 No Race - Required if student is in elementary or secondary education 15 No Ethnicity - Required if student is in elementary or secondary education 22 Yes Student with a Disability 96 No Start Date of Pre-Employment Transition Services 97-124 Yes Pre-Employment Transition Services 7 Note: Additional Data Elements are also reported (e.g., Program Year, Agency Code).

Participants In accordance with 34 C.F.R. 361.150(a)(1), for purposes of the VR program, an individual is a Participant if he or she has an approved IPE and is in receipt of VR services. When a student with a disability applies and is determined eligible for VR services, the VR agency is required to report additional Data Elements associated with that individual (e.g., dates of application, eligibility determination and IPE development). Once the individual becomes a Participant, all VR services, including Pre- Employment Transition Services, need to be provided under an approved IPE and reported accordingly. Data Element 74: State Definition for Age of Students with Disabilities At time of IPE. o The age range for the receipt of pre-employment transition services must be the same for both the General and Blind agencies, if a State has two agencies. 8

Data Element 22 Student with a Disability Report either at Application or Start Date of Pre-Employment Transition Services, whichever comes first. o 1 = Individual is a student with a disability and has a section 504 accommodation. o 2 = Individual is a student with a disability and is receiving transition services under an Individualized Education Program (IEP). o 3 = Individual is a student with a disability who does not have a section 504 accommodation and is not receiving services under an IEP. o 0 = Individual is not a student with a disability. VR agencies only report the age range and status as a student with a disability through RSA-911 reporting. Additional documentation related to the student should be included in the case file (e.g., disability documentation, enrollment in an educational program). VR agency policies should establish the age range and documentation required in the case file. Internal control processes ensure agency policies are accurately implemented. VR agencies must update DE 22 when individual ages out or no longer meets the definition of a student with a disability. 9

Data Element 96 Start Date of Pre-Employment Transition Services Report the date that the student with a disability received the first pre-employment transition service. o YYYYMMDD Reporting a date in DE 96 is required if the student is receiving pre-employment transition services. DE 96 is required regardless of whether the student is potentially eligible for the VR program (has not applied) or the student has applied or been determined eligible for VR services or has an approved IPE for VR services, including pre-employment transition services. 10

Pre-ETS Data Elements (1/5) For each of the five pre-employment transition service categories (Job Exploration Counseling, Work-Based Learning Experiences, Counseling on Enrollment Opportunities in comprehensive transition and postsecondary educational programs at institutions of higher education, Workplace Readiness Training, and Instruction in Self Advocacy), there are four corresponding Data Elements that may be reported in PD 19-03. As a result, there are 20 Data Elements for the various services. Changes to PD 19-03 included o Deletion of two data elements for comparable services and benefits providers for each category (under pre-employment transition services) o Deletion of Code Value 2 Requirement to report when service was no longer being provided 11

Pre-ETS Data Elements (2/5) To clarify, many Data Elements will be reported or remain blank, if the individual is not in receipt of pre-employment transition services during the reporting quarter. For example, if a student only receives job exploration counseling through the VR agency once, the agency reports a 1 for the code value for one DE. The other 19 possible DE are left blank. 12

Pre-ETS Data Elements (3/5) Data Element Name Report Unique Identifier Every Quarter 5 Social Security Number (if available) Every Quarter 6 Date of Birth Every Quarter 8 Sex Every Quarter 9 American Indian or Alaska Native Every Quarter 10 Asian Every Quarter 11 Black or African American Every Quarter 12 Native Hawaiian or Other Pacific Islander Every Quarter 13 White Every Quarter 14 Ethnicity - Hispanic or Latino Every Quarter 15 Student with a Disability Every Quarter 22 Start Date of Pre-Employment Transition Services Every Quarter 96 13

Pre-ETS Data Elements (4/5) Data Element Name Report Job Exploration Counseling Service Provided by VR Agency Staff (in-house) When Occurs 97 Job Exploration Counseling Service Provided Through VR Agency Purchase When Occurs 98 Job Exploration Counseling Purchased Service Provider Type When Occurs 99 Job Exploration Counseling VR Program Expenditure for Purchased Service When Occurs 100 Work Based Learning Experiences Service Provided by VR Agency Staff (in-house) When Occurs 103 Work Based Learning Experiences Service Provided Through VR Agency Purchase When Occurs 104 Work Based Learning Experiences Purchased Service Provider Type When Occurs 105 Work Based Learning Experiences VR Program Expenditure for Purchased Service When Occurs 106 Counseling on Enrollment Opportunities Service Provided by VR Agency Staff (in-house) When Occurs 109 Counseling on Enrollment Opportunities Service Provided Through VR Agency Purchase When Occurs 110 14

Pre-ETS Data Elements (5/5) Data Element Name Report Counseling on Enrollment Opportunities Purchased Service Provider Type When Occurs 111 Counseling on Enrollment Opportunities VR Program Expenditure for Purchased Service When Occurs 112 Workplace Readiness Training Service Provided by VR Agency Staff (in-house) When Occurs 115 Workplace Readiness Training Service Provided Through VR Agency Purchase When Occurs 116 Workplace Readiness Training Purchased Service Provider Type When Occurs 117 Workplace Readiness Training VR Program Expenditure for Purchased Service When Occurs 118 Instruction in Self Advocacy Service Provided by VR Agency Staff (in-house) When Occurs 121 Instruction in Self Advocacy Service Provided Through VR Agency Purchase When Occurs 122 Instruction in Self Advocacy Purchased Service Provider Type When Occurs 123 Instruction in Self Advocacy VR Program Expenditure for Purchased Service When Occurs 124 15

Reporting Pre-ETS Data Elements Accurately reporting the provision of pre- employment transition services requires multiple data elements. Student with a Disability For example: Start Date of Pre-ETS An individual is identified as a student with a disability (Reportable Individual or Participant). Start Date of Pre-ETS is reported (Reportable Individual or Participant). Pre-ETS (20 potential DE) If any Pre-ETS (20 potential DE) are reported, the start date must also be reported. In subsequent quarters, VR must report all applicable data elements,including the provision of any new Pre-ETS. Quarterly Reporting 16

Comparable Benefits RSA removed the requirement to report comparable benefits for all five required pre-employment transition services in PD 19-03; therefore, 10 fewer Data Elements are required: o Service Provided by Comparable Services or Benefits Providers (101, 107, 113, 119, 125) o Comparable Services or Benefits Provider Type (102, 108, 114, 120, 126) VR agencies must have policies and procedures in place related to their collaboration with state and local education agencies to provide pre-employment transition services and transition services. 17

Pre-ETS: Job Exploration Counseling DE Element Number Element Name Data Type Change (from PD1604) Report at Report Updateable after initial reporting (Y/N) Definitions or Instructions Code Values 97 Service Provided by VR Agency Staff (in house) INT 1 Yes Pre-ETS Data Elements Upon Occurrence Yes Report at the time the service is provided. 1 = Service was provided in whole or part by VR agency staff Leave blank if service was not provided by VR agency staff 98 Service Provided by Agency Purchase INT 1 Yes Upon Occurrence Yes Report at the time the service is provided. 1 = Service was provided in whole or part through purchase by the VR agency Leave blank if service was not provided through VR agency purchase. 99 Purchased Service Provider Type INT 1 No Upon Occurrence Yes If the service was provided in whole or part through purchase by the VR agency, the Purchased Service Provider Type must be reported. 1 = Public Community Rehabilitation Program (CRP) 2 = Private CRP 3 = Other Public Service Provider 4 = Other Private Service Provider Report the code value that best describes the primary service provider. Leave blank if service was not provided through purchase by VR agency. 100 VR Program Expenditure for Purchased Service INT 6 Yes Upon Occurrence Yes If the service was purchased by the agency, report the actual cost of a Job Exploration Counseling service. XXXXXX Report at the time the expenditure is paid. 18

Example: Pre-ETS Reporting Quarter 1 Agency Provided: Job Exploration Counseling In house Workplace Readiness Training Purchased Quarter 1 RSA-911 Report: Job Exploration Counseling In house DE 97 Workplace Readiness Training Purchased DE 116-118 Quarter 2 Agency Provided: Job Exploration Counseling Workplace Readiness Training Purchased Quarter 2 RSA-911 Report: Job Exploration Counseling Blank Workplace Readiness Training Purchased DE 116-118 Quarter 4 Agency Provided: Job Exploration Counseling Workplace Readiness Training WBLE Purchased Quarter 3 RSA-911 Report: Job Exploration Counseling In house DE 97 Workplace Readiness Training Blank WBLE Purchased DE 104-106 Quarter 3 Agency Provided: Job Exploration Counseling In house Workplace Readiness Training Work Based Learning Experience (WBLE) Purchased Quarter 4 RSA-911 Report: Job Exploration Counseling Blank Workplace Readiness Training Blank WBLE Purchased DE 104-106 19

Exiting as a Potentially Eligible Student For a student with a disability who solely received pre-employment transition services and who has not applied or been determined eligible to receive other VR services, the service record remains open until the individual no longer meets the definition of student with a disability. At that point, the agency cannot provide pre-employment transition services to the individual and RSA-911 reporting would end. However, if a student with a disability has applied and been determined eligible for VR services, the student s service record would be "closed" when the student satisfies the definition of "exit" at 34 C.F.R. 361.150(c) because his or her service record is closed pursuant to 34 C.F.R. 361.43 or 361.56. In PD 19-03, RSA deleted code value 8 (Potentially eligible individual exited after receiving pre-employment transition services and has not applied for VR services) in Data Element 354: Type of Exit. 20

Potentially Eligible Exit Data Elements When does RSA-911 reporting end for potentially eligible students with disabilities? PD 16-04 o DE 353: Date of Exit o DE 354: Type of Exit Code 8: Potentially eligible individual exited after receiving pre-employment transition services and has not applied for VR services o DE 355: Reason for Exit Code 19: All Other Reasons PD 19-03 o RSA-911 reporting ends when the individual no longer meets the definition of a student with a disability (e.g., ages out, not enrolled in an education program) and reporting of all expenditures has concluded. 21

Reporting Potentially Eligible Students Report all required DE for Reportable Individuals and student with a disability. Reportable Individual Report the start date and provision of Pre-Employment Transition Services (in-house or purchased). Pre-ETS Report when services were provided. Leave blank if service was not provided. RSA-911 reporting ends when individual no longer meets the definition of student with a disability. Quarterly Reports 22

Internal Controls Internal controls should ensure accurate tracking and reporting of all VR services, including pre-employment transition services, provided to students with disabilities through contracts or group services. Internal controls should prevent agencies from providing pre-employment transition services to individuals who do not meet the definition of a student with a disability. Data reporting internal controls should ensure that all VR services are listed on the IPE for participants, or other documentation such as case notes and records, for reportable individuals. o These controls should also ensure that VR services are not reported on the RSA-911 until they have been provided. (See Training #2 VR Expenditures) 23

RSA-911 Training Series 1. Background and Implementation 2. Reporting Expenditures for VR Services 3. Pre-Employment Transition Services (Pre-ETS) 4. Supported Employment (SE) Services 5. Measurable Skill Gains (MSG) and Credential Attainment 6. Exit and Post-Exit Data Elements 7. New Data Elements Additional Need to Know Information 8. RSA-911 Information Used in the WIOA Annual Report 24

Resources: Reporting VR Expenditures RSA s Comment Analysis (dated 01/25/2019) included in 30-day ICR Docket Folder https://www.regulations.gov/document?D=ED-2018-ICCD-0100-0032 RSA-PD-16-04 Case Service Report (RSA-911) https://www2.ed.gov/policy/speced/guid/rsa/subregulatory/pd-16-04.pdf RSA-PD-19-03 Case Service Report (RSA-911) https://www2.ed.gov/policy/speced/guid/rsa/subregulatory/pd-19-03.pdf RSA-PD-19-03 Case Service Report (RSA-911) in Excel file format 25

Contact Rimal Desai Management & Program Analyst (202) 245-6317 RSAData@ed.gov rsa.ed.gov Rachel Anderson (435) 764-8487 randerson@ndi-inc.org www.WINTAC.org 26