What is the Comprehensive Statewide Needs Assessment (CSNA)?
VR agencies must conduct a CSNA every three years. The VR agency and the State Rehabilitation Council (SRC) jointly develop the assessment 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 poorly understood. Gaining a clear understanding of the 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 entering and retaining quality employment outcomes.
Requirements for State Plan Description (b)
VR agencies must report on the results of the CSNA in Description (b) of the VR portion of the WIOA state plan; Description (b) must be based on a program year. (Note that all references to state plan descriptions have been updated for the PY 2024 state plans). The assessment 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 CSNA 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 RSA's 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 about 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, which is required to be conducted every three years at a minimum, must be submitted in Description (b) of the state plan, and 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 other words, VR agencies should update this Description, as appropriate, if the CSNA was conducted since the submission or modification of the prior State Plan. If the assessment was not updated since the submission or modification of the previous state plan, then Description (b) need not be submitted as part of the next state plan submission.
Implications for Other State Plan Descriptions
Although VR agencies are not required to include the full report of the CSNA in Description (b), agencies should thoroughly and clearly summarize the assessment results since this information serves as a foundation for the development of other state plan Descriptions. Specifically, Description (c) enumerates the VR agency’s goals, priorities, and strategies in carrying out the VR and supported employment programs required by 34 C.F.R. § 361.
34 CFR 361.29(c) and (d). The VR agency jointly develops these goals and priorities with the SRC. In addition to reviewing the results of the CSNA, the VR agency bases its goals and priorities on its performance on the standards and indicators established under Section 106 of the Rehabilitation Act and Section 116 of WIOA, the results of monitoring activities, and reports received from the SRC. Description (c) must be amended when there are updates to the CSNA.
Description (d) of the state plan also draws from the CSNA. This description includes an evaluation and reports of the progress toward achieving the VR agency’s goals and priorities. Specifically, VR Agencies should indicate whether goals are continuing into the next program year, are being revised, or are being retired based on information gathered through the CSNA.
An Important Note
Finally, note that newly established, developed, or improved community rehabilitation programs must be consistent with the results of the CSNA and with the requirements for the development and implementation of innovation and expansion activities. Furthermore, if a VR agency wishes to fund new projects requiring RSA prior approval (e.g., new innovation and expansion activities or third-party cooperative arrangements), the justification for funding these activities must be clear from a review of the summary of the CSNA.