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VR agencies must conduct a comprehensive statewide needs assessment (CSNA) every three years. The assessment is jointly developed by the VR agency and the State Rehabilitation Council (if the agency has a council). The requirements for this assessment can be found in 34 C.F.R. § 361.29(a). The requirement to conduct this assessment has been in the statute and regulations for years, but its importance is often underestimated and not well understood. Gaining a clear understanding of the rehabilitation needs of various populations of individuals with disabilities in the state will guide the VR agency in developing programs and services to better meet the needs of these populations and will ultimately contribute to greater numbers of individuals obtaining and retaining quality employment outcomes.

The CSNA must describe the rehabilitation needs of individuals with disabilities residing within the State, particularly the VR services needs of the following groups:

  • Individuals with the most significant disabilities, including their need for supported employment services;
  • Individuals with disabilities who are minorities and individuals with disabilities who have been unserved or underserved by the VR program;
  • Individuals with disabilities served through other components of the statewide Workforce Development System as identified by those individuals and personnel assisting those individuals through the components of the system; and
  • Youth with disabilities, and students with disabilities, including their need for pre-employment transition services or other transition services, and An assessment of the extent to which such services provided by VR agencies are coordinated with transition services provided under the Individuals with Disabilities Education Act. In addition, the comprehensive assessment must include an assessment of the need to establish, develop, or improve community rehabilitation programs within the State.

In 2009, through a contract with RSA, InfoUse produced an excellent guide to conducting the CSNA along with appendices and training materials. These materials can be found at the RSA website. While the Guide and Appendices have not been updated to include the new requirements for the assessment in the WIOA amendments of 2014, the recommended process for conducting the assessment is still appropriate. The new requirements are those pertaining to assessing the need for youth and students with disabilities for transition services and pre-employment transition services.

A summary of the results of the CSNA must be submitted in Description J of the State Plan. If updates are made to the assessment, the information must be incorporated into this description and submitted to RSA for approval with the submission or modification of the VR State Plan. In addition, if a VR agency wishes to fund new projects requiring RSA approval (e.g., new innovation and expansion activities or third-party cooperative arrangements), the justification for funding these activities must be incorporated into the summary of the CSNA submitted to RSA. Furthermore, information gathered in the CSNA forms the basis for the VR agency’s strategic planning and outcome and service estimates provided in other state plan descriptions.

The assessment results are critical as the VR agency develops and modifies other State Plan descriptions. Specifically, Description L enumerates the VR agency’s goals and priorities for the VR and supported employment programs required by 34 C.F.R. § 361.29(c) and must be updated with every submission and modification of the State Plan. Suppose the VR agency has an order of selection. In that case, it must identify its service and outcome goals and the time within which these goals may be achieved for individuals in each priority category within the order. Similarly, Description N requires VR agencies to list their goals and plans for distributing Title VI-supported employment funds. Information from the CSNA can guide the development of both descriptions. The VR agency jointly develops these goals and priorities with the State Rehabilitation Council. In addition to reviewing the results of the CSNA, the VR agency bases its goals and priorities on its performance on the performance indicators established under section 106 of the Rehabilitation Act and Section 116 of WIOA, the results of monitoring activities, and reports received from the State Rehabilitation Council.

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Another description relying on the CSNA results is Description O, which outlines the VR agency's strategies for addressing the goals and priorities it has set. Requirements for this description can be found in 34 C.F.R. § 361.29(b) and include:

  • The methods to be used to expand and improve services to individuals with disabilities, including how a broad range of assistive technology services and assistive technology devices will be provided to those individuals at each stage of the rehabilitation process and how those services and devices will be provided to individuals with disabilities on a statewide basis;
  • The methods to be used to improve and expand VR services for students with disabilities, including the coordination of services designed to facilitate the transition of such students from the receipt of educational services in school to postsecondary life, including the receipt of VR services, postsecondary education, employment, and pre-employment transition services;
  • Strategies developed and implemented to address the needs of students and youth with disabilities identified in the comprehensive assessments and strategies to achieve the goals and priorities identified to improve and expand VR services for students and youth with disabilities on a statewide basis;
  • Strategies to provide pre-employment transition services;
  • Outreach procedures to identify and serve individuals with disabilities who are minorities and individuals with disabilities who have been unserved or underserved by the VR program;
  • the VR agency’s plan for establishing, developing, or improving community rehabilitation programs, as applicable;
  • Strategies to improve the performance of the State VR agency with respect to the evaluation standards and performance indicators established pursuant to section 106 of the Rehabilitation Act and section 116 of WIOA; and
  • Strategies for assisting other components of the statewide workforce development system in assisting individuals with disabilities.

Description P of the State Plan, another description related to the CSNA, contains information on the evaluation of progress the agency has made with regard to its goals and priorities for the VR and supported employment programs reflected in both Descriptions L and N. The requirements for Description P stem from 34 C.F.R. § 361.29(e), and this State Plan description must summarize the results of an evaluation of the effectiveness of the VR program as well as a joint report by the VR agency and the State Rehabilitation Council on the progress made in improving the effectiveness of the program from the previous year.

More specifically, this report must contain:

  • An evaluation of the extent to which the VR agency’s goals and priorities were achieved;
  • A description of the strategies that contributed to the achievement of the goals and priorities;
  • To the extent to which the goals and priorities were not achieved, a description of the factors that impeded that achievement; and
  • An assessment of the performance of the VR agency on the performance indicators established pursuant to section 106 of the Rehabilitation Act and the performance accountability indicators required by Section 116 of WIOA.

In addition, the requirements in 34 C.F.R. § 361.29(b) on annual estimates are related to some of the information gathered through the CSNA. In particular, agencies on order of selection that are required to complete Description K need to provide the following estimates:

  • The number of individuals in the State who are eligible for VR services under 34 C.F.R. Part 361;
  • The number of individuals who are eligible for services but are not receiving such services due to an order of selection;
  • The number of eligible individuals who will receive services provided with funds provided under 34 C.F.R. Part 361 and under 34 C.F.R. Part 363, including, if the VR agency uses an order of selection, estimates of the number of individuals to be served under each priority category; and
  • The costs of the services, including, if the VR agency uses an order of selection, the service costs for each priority category.

Finally, the information the VR agency gathers through its CSNA will assist the agency in planning which special programs it might want to develop under the innovation and expansion authority or through cooperative arrangements with other agencies in the state.

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