Program-Specific Requirements for State Vocational Rehabilitation (Combined or General)
The Vocational Rehabilitation (VR) Services Portion of the Unified or Combined State Plan must include the following descriptions and estimates, as required by sections 101(a) and 606 of the Rehabilitation Act of 1973, as amended by title IV of WIOA.
a. State Rehabilitation Council.
1. All VR agencies, except for those that have an independent consumer-controlled commission, must have a State Rehabilitation Council (Council or SRC) that meets the criteria in Section 105 of the Rehabilitation Act. The designated State agency or designated State unit, as applicable, has:
Select A or B:
(A) is an independent State commission

(B) has established a State Rehabilitation Council
                        (B) has established a State Rehabilitation Council
2. In accordance with Assurance (a)(1)(B), if selected, please provide information on the current composition of the Council by representative type, including the term number of the representative, as applicable, and any vacancies, as well as the beginning dates of each representative’s term.
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Council Representative	Current Term Number/Vacant	Beginning Date of Term Mo./Yr.	
Statewide Independent Living Council (SILC)	1	December 2023	
Parent Training and Information Center	n/a	February 2024	
Client Assistance Program	n/a	December 2023	
Qualified Vocational Rehabilitation (VR) Counselor (Ex Officio if Employed by the VR Agency)	1	August 2023	
Community Rehabilitation Program Service Provider	2	October 2021	
Business, Industry, and Labor	1	October 2021	
Business, Industry, and Labor	2	September 2023	
Business, Industry, and Labor	1	August 2023	
Business, Industry, and Labor	1	August 2023	
Disability Advocacy Groups	2	October 2021	
Current or Former Applicants for, or Recipients of, VR services	1	August 2023	
Section 121 Project Directors in the State (as applicable)	n/a	n/a	
State Educational Agency Responsible for Students with Disabilities Eligible to Receive Services under Part B of the Individuals with Disabilities Education Act (IDEA)	1	August 2023	
State Workforce Development Board	1	February 2024	
VR Agency Director (Ex Officio)	n/a	July 2023	
Community Rehabilitation Program Service Provider	1	August 2023	
Disability Advocacy Groups	2	September 2023	
Due to size constraints in the above table, information for two additional Council Representatives continues below:
Other: Higher Education Representative, 2nd term, October 2021
Other: Special Education Representative, 1st term, October 2021
3. If the SRC is not meeting the composition requirements in Section 105(b) of the Rehabilitation Act and/or is not meeting quarterly as required in Section 105(f) of the Rehabilitation Act, provide the steps that the VR agency is taking to ensure it meets those requirements.
The West Virginia State Rehabilitation Council meets quarterly for a total of at least four meetings per year. Meetings may be added if necessary. WVDRS representatives attend and participate in all meetings of the SRC.
4. In accordance with the requirements in Section 101(a)(21)(A)(ii)(III) of the Rehabilitation Act, include a summary of the Council’s input (including how it was obtained) into the State Plan and any State Plan revisions, including recommendations from the Council's annual reports, the review and analysis of consumer satisfaction and other Council reports.
The West Virginia Division of Rehabilitation Services (WVDRS) received input from the West Virginia State Rehabilitation Council (WVSRC) members and chairperson regarding the Combined State Plan to be submitted by the Workforce Innovation and Opportunity Act (WIOA) partners in 2024. The input and the agency responses are reported below.
Observation 1: The partnership between West Virginia Division of Rehabilitation Services (WV DRS), the WV Department of Education (DOE), WV Schools for the Deaf and the Blind (WV SDB), Workforce Investment and Opportunity Act (WIOA) partners create a valuable community for people with disabilities. WV DRS continues to have successful outreach to students with disabilities from ages 14 – 21 to encourage increased enrollment at a younger age for VR services, like pre-employment transition services (Pre-ETS) to achieve vocational training, postsecondary education, and employment goals. WV SRC recognizes the inclusion of their partnerships and CRPs on the “Pathways to the Future” website (pathwayswv.org) and looks forward to seeing additional growth in this area.
Recommendation 1: The WV SRC recommends WV DRS continue longitudinal tracking with WIOA measurements to highlight the benefits of Pre-ETS and VR services for the students’ long-term success. WV DRS has increased communication efforts with their long standing and newly innovated partnerships who can offer additional support for students’ continuation of care. WV DRS could bring in the local agencies, councils, partners, and programs, like CRPs, at the end of their Pre-ETS camps or have their booths at the Pre-ETS camps. These WV DRS connections aid students to receive more services, more frequently, from this evolved community of support. The ongoing communication and collaborative efforts made by WV DRS are beneficial for students throughout the 55 counties of WV.
Observation 2: WV DRS prioritizes people with disabilities to go through the application and enrollment process to receive individualized services as soon as possible. This is evident as WV DRS continues in their innovative efforts to serve students during their secondary education, as young as 14 years of age. The Individual Plan for Employment (IPE) will promote the student to get on board and include VR services while identifying their future goals.
Recommendation 2: The WV SRC recommends that WV DRS continues their frequent presence in high schools and/or vocational schools. Having VR Counselors available to inform students on all the WV DRS services and programs will give the students a variety of choices on what to incorporate into their IPE. Keeping the students well informed allows them to have ownership of their personalized IPE. Building awareness of WV DRS services is also crucial in non-traditional educational settings, such as Home Schools. WV DRS counselors have opportunities to assess the needs of students’ families for additional supportive programs from WV DRS and their partners.
Observation 3: There has been an increased awareness of how effective communication between first responders and people with disabilities is vital. WV DRS continues to empower individuals with varying disabilities to live more independently, including driving and excelling in their career goals. There have been noticeable efforts from WV DRS to assure their consumers have a multitude of resources to achieve their goals. One of these efforts can be seen on the WV DRS website’s Consumer Affairs Committees (CAC) page, which reads, “The committees’ activities focus on a broad range of goals, including public awareness and support for the rights, individual dignity, personal responsibility, full inclusion, equal access, self-determination, and community involvement of people with disabilities.”
Recommendation 3: The WV SRC recommends that WV DRS has their Consumer Affairs Committees collaborate with partners, such as the WV Department of Education (DOE), West Virginia Schools for the Deaf and the Blind, WorkForce, and additional partners as needed, to create materials for effective communication between first responders and people with disabilities statewide. The WV SRC and partnering councils, such as WV SILC could provide support in this endeavor as well.
After further discussion with CSAVR Director, she described training programs that have been created, alongside law enforcement, for disability awareness with an emphasis on effective communication and interaction. One specific example can be seen on the Oklahoma Department of Rehabilitation Services website (https://oklahoma.gov/okWVDRS/newsroom/2023/09/sdhhdeafawarenessweek.html). David Hankinson is a Program Manager, from the Services to the Deaf and Hard of Hearing (SDHH), within the Oklahoma WVDRS VR division. The Oklahoma School for the Deaf also provided support with SDHH and OK WVDRS to collaboratively work with law enforcement to create laminated “police communication cards.” These cards were distributed in 2023 for free, during Deaf Awareness Week, in September. The laminated card is something that people who are hearing impaired can keep in their car visor for easy access, which can be used for other first responders, for effective communication. This allows for the person with hearing impairments to point out on the laminated card to items, like their preferred way of communication, if they need roadside assistance, or emergency medical attention. The first responder can also point to the card to communicate why the individual is being stopped, if they need to see identification, and additional commands. Hankinson explained that first responders’ interactions can cause misunderstandings and frustration on both sides; especially if there is a flashlight obstructing the person with hearing impairments to not see the queues or read lips, possibly leaving the officer to assume they are being intentionally non-compliant. If a person who is hard of hearing relies on sign language, but their interaction leads to handcuffs, they are physically silenced. WV DRS has the resources and support to create a variety of first responder, community, and employment communication cards to reduce barriers experienced by people with disabilities (vision, hearing, etc.). This initiative would build a relationship with first responders, increase community awareness statewide, create promotional opportunities, but most importantly – empower individuals with disabilities.
Observation 4: WV DRS continues collaborative efforts with partners at WorkForce, WV DOE, WV SDB, CRPs, councils, and local agencies who can optimize an individual’s independence and provide support in helping someone maximize their employment opportunities and income. These programs can help individuals achieve their employment goals, which increase career options through local connections (especially in rural areas). Stronger collaboration promotes employment sustainability for consumers with a significant disability. This previous observation has been expanded since there has been a noticeable decline in “Performance Indicator 1.4 – Significance of Disability” which measures the percentage of consumers with a significant disability to earn at least minimum wage. Even though the measurement was less than 5% shy of RSA’s federal benchmark of 62.4%; there has been a significant decline from FY 2019 being at 99.4% to FY 2022 reporting at 57.7%. This goal was understandably impacted during the global COVID 19 pandemic as the economy continues in the recovery process.
Recommendation 4: WV SRC recommends WV DRS and consumers to benefit from all the effort WV DRS has put in to building better relationships with partners at WorkForce, WV DOE, WV SDB, CRPs, councils, and local agencies. WV SRC commends WV DRS in their ongoing and newer strategies, like hosting Quarterly CRP Meetings. WV SRC recommends WV DRS have an updated supportive services summary sheet, categorized, and divided by region, to be made easily accessible on WV DRS website for potential and current consumers. WV DRS Counselors could provide this updated supportive services summary sheet along with WV DRS handouts to offer additional services to encourage employment retention and continued support.
Observation 5: WV DRS continues collaboration with WIOA partners, such as when WV DRS hosted the first-ever WIOA Partners Conference in June of 2022 to enhance teamwork and coordination with hundreds of participants from WIOA partners and stakeholders. WV DRS has an opportunity to further integrate and coordinate with WIOA program partners on WIOA common performance measures, such as the Measurable Skills Gain Rate measure. The American Job Centers (AJC) buildings house WorkForce programs, as well as other community partners. There is a WV DRS office in AJC buildings, such as the Kanawha County location.
Recommendation 5: WV SRC recommends WV DRS coordinate with WIOA program partners for historical knowledge on WIOA common performance measures for leverage and reuse of resources and methodologies. This will further prepare WV DRS consumers while increasing measures, like the Measurable Skills Gain Rate. WV DRS will build onto their top-tier services with educational, skills, employment, and networking opportunities. Since the relationship pre-exists between WV DRS and WIOA partners (e.g., AJC) this would be a streamlined process for the most elite toolkit to benefit WV DRS and consumers.
Observation 6: Persistent efforts needed for competitive long-term employment in the business industry. This was another area impacted nationally by the COVID 19 Pandemic and was reflected in the Performance Indicator 1.6 — Self-Support. This measured consumers whose earnings were at least minimum wage, the difference in the percentage of individuals who at program entry reported their income as the largest single source of support, and the percentage that reported their personal income as the largest single source of support at program exit. (Federal Requirement – 53% mathematical differences). WV DRS reported above the federal benchmark in FY 2019 at 62.9% but in FY 2022 it was 37.5% - causing a 15.5% gap in meeting the federal standard, which is a national, if not global issue, deriving from the job market and economy shift during and post-COVID 19. The pandemic also impacted reporting from the mandated social distancing policies with the service industry and virtual schooling inevitably posing as a problem for this measurement.
Recommendation 6: The WV SRC recommends the continuation of educating and showcasing businesses who integrate WV DRS consumers as noted in the “WV DRS Annual Report 2022.” - There were barrier shattering accomplishments by WV DRS Employment Services Unit for FY 2022. Some of these accomplishments include increasing business engagement strategies like joining the Chamber of Commerce to more than double employment opportunities for individuals with disabilities in On-the-Job Trainings (OJT); implementing an Employer Recognition Program; Providing a comprehensive two-day disability inclusion training from WINDMILLS; and many more. WV SRC encourages WV DRS to continue conducting workshops and include firsthand testimonials in email blasts. Coordinating WV DRS presence with local organizations, such as the Charleston Area Alliance who hosts monthly “Business After Hours” social events. There are also WV One Stop Business Center locations that are frequented by new and established businesses owners. Additional income opportunities for those qualifying for WVABLE is another program WV DRS partners with and should continue to encourage consumers to include WVABLE as a resource for financial support.
Observation 7:  WV DRS has opportunities to raise awareness of their consumers’ vocational rehabilitation and successful careers. Having this additional knowledge spread throughout our state lowers barriers for people with disabilities and raises opportunities in the community. WV DRS has proven this ongoing initiative from the success for job opportunities derived when joining a local Chamber of Commerce, more than doubling On-the-Job Training (OJT) for people with disabilities.
Recommendation 7: WV SRC recommends WV DRS have a publicity committee established, or rejuvenated to boost publication efforts through websites, newspaper articles, statewide magazine advertisements, and being more active on social media platforms. Public broadcasting on local news channels can be increased, especially for special events, like the WV DRS Annual Ability Works Ceremony, and the Annual Essay Contest. Further opportunities and services will be made available to people with disabilities as communities witness the WV DRS consumer success stories.
Observation 8: WV DRS has been working with The Behavioral Health, Corrections, and Community Assets Programs and other agencies to provide information on WV DRS programs and services. WV DRS Counselors have also received resources to offer to consumers involved in the criminal justice system. This networking has assisted consumers with co-occurring conditions, such as mental health and substance related disorders to manage barriers and achieve employment goals.
Recommendation 8: The WV SRC recommends WV DRS continues working together with active participation in Behavioral Health Planning Council, WV Olmstead Council, WV Achieving a Better Life Experience (WVABLE) Advisory Committee, Developmental Disabilities Council, Traumatic Brain Injury Advisory Board, Fair Shake Network, Dangerous Assessment Advisory Board, Bridging Resources West Virginia Advisory Committee, the Creating Opportunities for Recovery Employment (CORE) Regional Advisory Council, and Jobs and Hope program. WV SRC recommends expanding these endeavors, like Jobs and Hope, to the known underserved areas with transportation barriers. WV SRC is interested in reviewing additional reporting deriving from these impressive partnerships to combat this complex crisis.
Observation 9: WV DRS consumers typically need a variety of transportation methods, depending on their short-term and long-term goals. Some consumers may require public transportation education until they can afford a vehicle, regain their driving privileges, and/or have vehicle modifications. Others will benefit from options, such as transportation services programs, or drivers’ education and tutoring. WV DRS consumers receive support to increase independence with programs such as the Rehabilitation Technology Unit who travel across the state to provide accommodation services and driving instructors. This unit offers continued training, such as self-advocacy, workplace readiness, money management, driver education and training for various modes of transportation.
Recommendation 9: WV SRC recommends WV DRS continues growing programs, such as the Rehabilitation Technology Unit. WV DRS counselors should be well informed of the more unique services, such as vehicle modifications, accommodation services, and driving instructors. WV DRS impresses the importance of employment, so incorporating preparation for the appropriate transportation resource is crucial for the consumers’ careers and independence. WV DRS consumers would benefit from education of the public transportation system, specifically for people with visual, hearing, or mobility classified disabilities.
WV SRC recommends WV DRS research Driving Simulators, including Commercial Driver License (CDL) Training Simulators (e.g., WVU Occupational Therapy and WV Community College). These additional driving training opportunities would significantly increase skills and confidence in WV DRS consumers to go into careers requiring specialized driving operational licenses, like CDLs.
Observation 10: WV DRS continues to host dynamic and impactful conferences for internal training and collaboration with partners. This large undertaking assures knowledge of the services and programs available from WV DRS and their abundant amount of collaborations are known internally and across the rehabilitation network in West Virginia. A healthy company culture increases productivity, which can also be seen in the high quality of services provided to WV DRS consumers.
Recommendation 10: WV SRC recommends WV DRS to continue hosting valuable conferences and training courses with their partners and CRPs, as well as internally. These events and recurring meetings provide a platform to encourage a positive working culture of appreciation. Having key-note speakers can re-ignite passion and purpose. WV SRC recommends incorporating feedback from the WV DRS consumers’ real-life experiences to WV DRS internally. This effort would be another source of encouragement, like the success stories shared at the Ability Works Ceremony. WV SRC recommends WV DRS have a publicity committee established. WV DRS also has self-advocacy training for consumers. Encouraging WV DRS consumers in self-advocacy training to communicate on the barriers they are overcoming and their successes along the way will increase their self-advocacy skills. Connecting these WV DRS consumers to an internal publicity committee would allow them to confidently use their voice. Utilizing opportunities like this will support recognition for the valuable work of the WV DRS staff as well; and share knowledge of consumer services available.
CONSUMER SATISFACTION
As part of its program improvement efforts, WVDRS continued to support the implementation of consumer satisfaction surveys of its clients to ensure quality services for WVDRS consumers. The WV State Rehabilitation Council (WVSRC) conducted the surveys (with full WVDRS assistance and cooperation). WVSRC is primarily responsible for completion of the consumer satisfaction survey for Vocational Rehabilitation (VR) consumers. WVDRS continued to provide and supplement fiscal and human resources needed for its successful completion. WVSRC members selected a survey method that allowed former WVDRS clients and individuals who were not accepted for VR services to be contacted via mail surveys as soon as they exit WVDRS from various statuses throughout the fiscal year. The findings were based on consumer satisfaction information gathered from 211 responses across the six WVDRS districts. Respondents to the consumer satisfaction survey were asked to rate their agreement with statements about their interactions with WVDRS. The ratings were “strongly agree,” “agree,” “neutral,” “disagree,” and “strongly disagree.” Respondents were provided an option to indicate replies that were neutral or that the survey item was not applicable. Selected highlights of the December 2022 Consumer Satisfaction Survey of WVDRS clients as reported by the WVSRC were: Overall, responses for the 2021-2022 survey were slightly higher than the reported satisfaction in previous years. The mean rating across the ten satisfaction items was 88% for 2021-22, compared to 86% for 2020-21, 86% for 2019-20, 80% for 2018-19, 78% for 2017-18, and 76% for 2016-17. Major findings of the consumer satisfaction survey included: (1) respondents felt their rehabilitation counselor treated them with respect (94%), (2) they felt that the eligibility requirements and process for receiving services were clearly explained by WVDRS staff (94%), (3) their questions were answered clearly by WVDRS (93%), (4) they received the services they needed (90%), and (5) they were satisfied with the services provided (90%). Respondents also reported that their counselor stayed in contact, so they knew what was happening (89%) and that they were made aware of the steps and responsibilities to achieve their employment goal (89%). Consumers also reported high ratings (“Above Average” or “Excellent”) for accessibility of local offices (95%), and the overall experience with WVDRS (91%).
STRATEGIC PLANNING
Strategic planning discussions occur on a regular basis at WVDRS Executive Management Group meetings, which include representatives of the SRC and Statewide Independent Living Council (SILC), as appropriate. Needs assessment results are shared with the SRC and SILC. WVDRS Goals and Priorities were presented at meetings of the SRC, where the SRC has opportunities for input. The SRC meetings include a variety of stakeholders, including representatives from the Client Assistance Program, SILC, other state agencies, and stakeholders.
To ensure transparency and public awareness regarding the Program Year (PY) 2024 VR portion of the WV Combined State Plan, WVDRS posted a draft version on the agency’s website for review.
The West Virginia Division of Rehabilitation Services (WVDRS) held a public meeting on the Vocational Rehabilitation portion of the WV Combined State Plan for Program Years 2024-2027 on December 19, 2023 to receive comments and questions from VR stakeholders pertaining to the Vocational Rehabilitation Portion of the Combined State Plan. The meeting was publicized on both the WV Secretary of State’s and WVDRS’ websites.  The meeting was also announced during stakeholder meetings and emails to stakeholders, including the WV State Rehabilitation Council and the Client Assistance Program. Thirteen individuals attended the meeting either in person or virtually. DRS also held a public comment period on the Vocational Rehabilitation portion of the WV Combined State Plan for Program Years 2024-2027 from December 11, 2023-January 10, 2024. Disability Rights of West Virginia (DRWV), the federally mandated protection and advocacy system for the state of West Virginia, submitted comments on the VR Portion; there were no other comments received. The following is a summary of the comments received from DRWV and the WVDRS responses to the comments.
DRWV Comment:
Page 6: WVDRS Response to Observation/Recommendation 2: “WVDRS agrees that it is important for students and youth with disabilities to begin the vocational rehabilitation process as early as appropriate after reaching 14 years of age. WVDRS is open to the recommendation and has requested that counselors identify any possible opportunities for additional embedded VR offices within high schools. WVDRS continues to maintain an office on campus at the WV Schools for the Deaf and Blind to provide awareness and services, including PreETS, in an expeditious manner. If additional opportunities arise, WVDRS will move forward to establish offices, where appropriate and agreed upon by both parties.” DRWV also agrees that it’s important for students and youth with disabilities to begin vocational rehabilitation services as early as appropriate after reaching 14 years of age. However, while providing advocacy services throughout the state of WV, DRWV has become aware of gaps in DRS services. DRWV recommends that DRS work closely with the Local Educational Agency (LEA) to educate parents, students, and school personnel on DRS services and eligibility requirements. DRS could set up resource tables and/or request time on assembly agendas during open houses, Local School Improvement Council (LSIC) meetings, and /or parent resource fairs.  In addition, most LEAs have a communication system that regularly sends information blast to parents, students, and school personnel.  DRS could request the LEA to share information regarding DRS services. There are many students across West Virginia who are enrolled in public schools and some students who receive services in facilities that could benefit from DRS services, but the information is not readily available. DRWV believes that there are opportunities for DRS to have a meaningful presence at LEAs. However, it appears that DRS Counselors mostly visit schools to attend IEP meetings for a few students but have no other interaction with potential clients.
WVDRS Response:
WVDRS has a long history of serving students and transitioning youth with disabilities and has sustained this focus through the continued implementation of the Workforce Innovation and Opportunity Act. WVDRS’ ongoing efforts are evidenced by the large percentage of applicants who are students with disabilities, which comprise over half of all individuals who apply for and receive WVDRS services. WVDRS serves students with disabilities who are enrolled in both public and private schools, homeschool, and other educational settings. 
WVDRS maintains formal interagency agreements with the WV Department of Education, the WV Schools for the Deaf and the Blind, and each of the 55 county boards of education. For many years, WVDRS has assigned a vocational rehabilitation counselor to each public high school in the state, and this practice continues today.
WVDRS and Education have a shared partnership and shared responsibility to students with disabilities, and WVDRS takes its role to fully engage with and supplement education for students and transitioning youth with disabilities very seriously. Through the Systemic Transition Enhancement Project starting in 2021 (STEP21) initiative, WVDRS has encouraged full participation from our partners, stakeholders, staff, and our consumers to increase awareness of the availability of our services and to advance high-quality employment outcomes for participating students with disabilities.
WVDRS works with the WV Department of Education (WVDE), Office of Special Education to cross train WVDRS and Education staff, including special education coordinators and teachers. WVDRS also works with WVDE to develop and disseminate outreach materials to students with disabilities and their parents, grandparents, and/or guardians. Special Education staff across the state have been trained on the use of PathwaysWV.org, WVDRS’ website, which targets students with disabilities, their parents/guardians, and Education staff.
As part of the STEP21 initiative, WVDRS renewed its commitment to maximize outreach and services to students with disabilities, while calling on stakeholders, including the school system, to assist WVDRS with its outreach and referral efforts. Additionally, WVDRS conducts a variety of outreach efforts across the state that vary by county and school. These activities include outreach by WVDRS and/or Education staff and are not limited to parents’ nights, transition fairs, job fairs, and community and sporting events. For over five years, WVDRS has provided large informational banners to all public high schools in the state to be placed in high traffic areas of the schools. The banners target high school students with disabilities and provide a summary of WVDRS' services, DRS contact information, website address, and a QR code to allow smartphone users to quickly access the WVDRS website.
WVDRS rehabilitation professionals do attend IEP meetings whenever invited (WVDRS staff cannot attend unless invited), but as illustrated, these meetings are not the only WVDRS presence within West Virginia's educational system.
DRWV Comment:
Page 7: continue WVDRS Response to Observation/Recommendation 2: “Additionally, WVDRS has made concerted efforts to provide outreach and services to nontraditional education settings for youth with disabilities, such as juvenile centers and facilities, Youth Reporting Centers, and other similar locations. The youth in these settings are afforded the same opportunity to receive Pre-ETS and other VR services as individuals in traditional settings, as appropriate. Further outreach continues to be conducted with stakeholder groups, such as parent and grandparent organizations, to include those students who may be in homeschool, private school, or other educational settings.” DRWV’s direct advocacy with youth with disabilities in non-traditional education settings has NOT shown that DRS provides the same outreach and services to these individuals. Often the facility staff are not familiar with DRS services. DRWV recommends that DRS becomes actively involved, responsive, and work closely with the Youth Transitional Facilities and private and state Children’s Residential Facilities.
WVDRS Response:
In recent years, WVDRS Director Bua-Iam launched a targeted outreach effort to increase awareness of its services to individuals working and residing in Youth Transitional Facilities, state Children's Residential Facilities, and other nontraditional educational settings. The initial efforts were conducted in conjunction with a DRWV staff attorney, who was also member of the WV State Rehabilitation Council during this time, WVDRS' Program Specialist over Behavioral Health/Corrections/Community Assets, and local WVDRS rehabilitation counselors and managers. After the initial outreach process, which included direct contact with all related facilities, WVDRS staff continue to visit and meet with potential consumers and facility staff. As always, WVDRS is ready and willing to act on any specific information regarding potential locations where additional outreach may benefit potential consumers.
DRWV Comment:
Page 8: WVDRS Response to Observation/Recommendation 3: “WVDRS is in agreement with the benefits of materials that enhance the communication between individuals with disabilities and first responders. The agency appreciates the research and examples provided by the SRC, CSAVR, and other VR agencies. WVDRS will work with its CACs, and other stakeholders including the SRC, to explore the development, creation, and distribution of materials that would afford more effective communication between first responders and people with disabilities statewide, as appropriate.” DRWV developed an EMS Communication Card with WVU CED, National Down Syndrome Society, City of St. Albans Fire Rescue, WV Commission for the Deaf and Hard of Hearing. There is also a D/HH Visor Card for use by a Deaf or Hard of Hearing individual in a vehicle. This material that has already been developed may be of assistance to DRS and its clients.  DRWV shared electronic and physical copies of this material.  
WVDRS Response:
WVDRS greatly appreciates DRWV providing these valuable materials to assist individuals with disabilities across the state with communicating with first responders. WVDRS will make those materials, in both electronic and physical forms, available to its consumers and other stakeholders whenever appropriate and allowable.
DRWV Comment:
Page 14: of the VR Portion of the WV Unified State Plan for Program Years 2020-2023, effective beginning July 1, 2020: “DRS also maintains communication and works with other non-educational agencies that serve out-of-school youth in order to introduce and provide VR services. These agencies include Youth Reporting Centers under the WV Division of Juvenile Services and Peer Support Centers, funded by the WV Bureau for Behavioral Health. Youth Reporting Centers are community-based centers that provide intervention programs for at-risk youth and also provide reintegration services for youth returning to the community. The Peer Support Centers provide a variety of support services for qualifying youth with behavioral health conditions.” Page 13: of the draft Vocational Rehabilitation Portion of the WV Combined State Plan for Program Years 2024-2027, 4. Non-Educational Agencies Serving Out-Of-School Youth: DRWV questions the removal of language outlined in the PY 2020-2023 plan.  It appears DRS has transferred all efforts to introduce and provide VR services to Workforce Innovation and Opportunity Act (WIOA) partners.
WVDRS Response:
WVDRS appreciates the opportunity to clarify the referenced section of the VR Portion of the WV Combined State Plan. To be clear, WVDRS has not "transferred all efforts to introduce and provide VR services to Workforce Innovation and Opportunity Act (WIOA) partners." This section of the VR Portion of the WV Combined State Plan requires DRS to describe its interagency cooperation with other agencies, including those noneducational agencies serving out-of-school youth (a separate and distinct population served by a required program under Title I of WIOA and administered by the U.S. Department of Labor at the federal level and by WorkForce WV in West Virginia). This program is required to serve youth who are not enrolled in certain educational or training programs. Participants and potential participants of this program may also have disabilities, making them potentially eligible for VR services through WVDRS. Because of these potential VR consumers, WVDRS works with this program to coordinate outreach and referrals. Furthermore, WorkForce WV and WVDRS strive to co-serve eligible individuals, whenever appropriate and allowable, to maximize services, resources, and expertise to increase quality employment outcomes.
DRWV Comment:
Page 15: Subminimum Wage Employment: “Section 511 of the WIOA imposes requirements on WVDE and Rehabilitation with regard to youth with disabilities seeking subminimum wage employment. Rehabilitation and WVDE shall work cooperatively to ensure that the individual, before beginning work that is compensated at a subminimum wage, has completed, and produces documentation indicating completion of, each of the following actions…” DRWV would like to know why DRS is promoting subminimum wage employment to students. DRWV suggests that DRS educate students about competitive integrated employment. According to the US Department of Labor’s website list of 14c Certificate holders, there is only one employer that is listed from WV with a current certificate to allow subminimum wage. It would be more in line with the current Employment First framework to promote competitive pay for all people with disabilities.
WVDRS Response:
WVDRS appreciates the opportunity to clarify this section of the VR Portion of the WV Combined State Plan. This section references a federal requirement of the formal interagency agreement between WVDRS and the WV Department of Education to address Section 511 of the Rehabilitation Act [Title IV of WIOA; see 34 C.F.R. §361.22(b)(6), 34 C.F.R §397.31, and 34 C.F.R. §397.5(d)] regarding subminimum wage employment, specifically students and youth with disabilities seeking subminimum wage employment. 
As the state agency responsible for administering the WIOA Title IV Vocational Rehabilitation program, WVDRS is not permitted to assist individuals with disabilities, including students and youth, with gaining or maintaining subminimum wage employment. WVDRS only serves eligible individuals with disabilities seeking competitive integrated employment, which supports the employment first philosophy. WVDRS is also an active member of the West Virginia Employment First Task Force.
Additionally, as required by Section 511, WVDRS regularly provides information and resources regarding competitive integrated employment and available vocational rehabilitation services to all individuals with disabilities in the state working in subminimum wage employment under a 14(c) certificate holder. 
DRWV Comment:
Page 17: “As part of the Comprehensive Statewide Needs Assessment (CSNA), WVDRS attempted a one-on-one Pre-ETS needs assessment discussion with teachers and administrators in all of West Virginia’s 55 counties. WVDRS received participation from 64 high schools in 29 (out of 55) counties in 2023.” The VR Portion of the WV Unified State Plan for Program Years 2020-2023, effective beginning July 1, 2020, referenced a 2019 joint training with the WV Office of Special Education, that included cross training for over 200 staff.” What efforts were made in 2023 to reach all high schools, non-traditional educational settings, and the WV Office of Special Education? It appears that the 2019 training was relatively successful. DRWV recommends that DRS make all attempts necessary to train all stakeholders. 
WVDRS Response:
As previously mentioned, WVDRS conducts outreach in a variety of ways. This includes direct outreach by vocational rehabilitation counselors, large informational banners in high schools, outreach by state-level staff including the Program Specialist over Behavioral Health/Corrections/Community Assets and a full-time outreach coordinator. As part of the CSNA, WVDRS relied on a variety of methods from its own staff and through coordinated efforts with state and local level partners. This included direct, in-person and email efforts. While WVDRS would prefer more respondents, participation in the CSNA is completely voluntary, and we greatly appreciate all respondents to the CSNA, including those who serve students with disabilities. 
WVDRS agrees with the benefits of cross training staff from other agencies and continues to do so on local and state levels. For example, DRS hosted a partner agency conference with attendees from over 80 different agencies/programs. During the conference, each agency/program was afforded the opportunity to present information about their agency/program to the entire audience and have informational tables set up for the duration of the conference. Conference attendees included representatives from the WV Department of Education, Office of Special Education and other agencies and programs that serve individuals with disabilities.
DRWV Comment:
Page 19: Transition and Pre-Employment Transition Services Planning: “The participation of Rehabilitation counselors, or other Rehabilitation staff, as appropriate, in the IEP process will help students and parents understand the differences in and facilitate the provision of educational and rehabilitation services.” As mentioned during the public comment session held on December 19, 2023,” DRWV recommends that “other Rehabilitation staff,” be defined. DRWV has concerns with the vague reference of “other Rehabilitation staff” language. DRWV believes that DRS clients could potentially be at risk of receiving services from unqualified DRS staff.
WVDRS Response:
WVDRS appreciates the opportunity to clarify this section of the VR Portion of the WV Combined State Plan. As described in the quoted section above, WVDRS utilizes its staff, as appropriate, to attend IEP meetings to inform students and parents about VR services and what type of services may be the responsibility of WVDRS and those that may be the responsibility of the LEA. While WVDRS has a Rehabilitation Counselor assigned to each high school in the state, the number and timing of IEP meetings greatly exceeds the capacity of its VR counselors to attend every IPE meeting. To maximize its presence at IEP meetings, WVDRS utilizes other staff, including District Managers and Branch Office Managers (all former Rehabilitation Counselors) and Rehabilitation Services Associates (RSA), which are paraprofessionals who assist Rehabilitation Counselors. To be clear, there is no risk of any consumer being provided services from unqualified WVDRS staff. Rehabilitation Counselors, including those in management positions, are the only WVDRS staff permitted to conduct certain activities and provide certain services to WVDRS consumers. This includes determining eligibility and the development and implementation of the Individualized Plan for Employment (IPE). To maximize efficiency with existing human and fiscal resources, other WVDRS staff, including RSAs and Employment Specialists, may assist the Rehabilitation Counselor with various clerical and paraprofessional aspects of casework and service provision. However, the Rehabilitation Counselor is responsible for overseeing consumers' cases.
DRWV Comment:
Page 22: Outreach and Identification: “Outreach activities and student identification will be conducted as early as possible, preferably no later than the students' 10th grade year and shall include…" DRWV suggest that DRS focus on the student’s age and not the grade.  If the LEA has a requirement to begin transition services at age 14, and DRS is an important part of transition services it seems as though DRS would want to train and educate potential clients as soon as possible. There are some 9th graders who are 14 years of age. If DRS waits until the student is in the 10th grade, then an entire school year will be missed.
WVDRS Response:
WVDRS appreciates this opportunity to clarify that this language is an excerpt from its interagency agreement with the WV Department of Education (WVDE), which primarily focuses on coordinated efforts and is not exhaustive of WVDRS' additional efforts and activities outside the scope of the agreement with WVDE. WVDRS is required to have an agreement with WVDE and that agreement must contain certain information and certain sections of this agreement are required to be included in the VR Portion of the WV Combined State Plan and the referenced section is a reflection of WVDRS' response to those requirements. In accordance with federal regulations and the state definition of "student with a disability," WVDRS only provides services to individuals who are a minimum of 14 years of age. As quoted above from the interagency agreement between WVDRS and the WVDE, outreach activities begin and student identification is conducted as early as possible. WVDRS does not have a grade-level requirement and actively and fully serves students with disabilities prior to their 10th grade year, including students aged 14 and above who are currently enrolled in the 9th grade or below (e.g., middle school).
DRWV Comment:
Page 95: Order of Selection: “The Counselor will determine the significance of an individual’s disability after conducting a diagnostic study that allows for assessing the permanency of the disability, the number of functional capacities limited by the disability, the number of vocational rehabilitation (VR) services needed, and the time in service required to complete those services. These criteria are used when determining whether the individual’s disability is non-significant, significant, or most significant.” DRWV believes that the language could be misleading and gives the impression that the counselor has the absolute authority to make disability determinations based on vague guidelines and limited information.
WVDRS Response:
WVDRS appreciates the opportunity to clarify the Order of Selection section of the VR Portion of the WV Combined State Plan. As outlined in the VR Portion, as well as the WVDRS Client Services Manual, which is available on the WVDRS website, a Rehabilitation Counselor does not and cannot base the significance of disability on vague guidelines and/or limited information. In 2020, WVDRS revised the previous Order of Selection categories and their respective definitions per request of the federal Rehabilitation Services Administration (RSA). At the time, WVDRS held a public meeting and a public comment period to provide an opportunity for feedback on the RSA-approved changes. After reviewing the full content of the VR Portion of the WV Combined State Plan and WVDRS policy, WVDRS is confident that the specific requirements and definitions are clear to consumers, stakeholders, and the general public.
DRWV Comment:
Page 3: Recommendation 4: “WV SRC recommends WV DRS have an updated supportive services summary sheet, categorized, and divided by region, to be made easily accessible on WV DRS website for potential and current consumers.” Page 7: WVDRS Response to Observation/Recommendation 4: “The agency is currently in the process of developing a fully redesigned, accessible website that will allow for easier navigation, including information about available services. WVDRS will notify the SRC when the new site is ready for demonstration.”  It is DRWV’s opinion that the WVDRS website (www.wvdrs.org) is not user friendly and is incredibly outdated. DRWV understands that DRS is in the process of developing a new website. However, DRWV would like to know if there a time frame for updating the website. 
WVDRS Response:
WVDRS has been working with an outside firm to create a new website. The website will be accessible and more user-friendly to all users, including those using smart phones and tablets. Presently, the site is nearing completion and is in the quality assurance review stage. WVDRS anticipates the new site going public prior to March 2024.
DRWV Comment:
In addition, after reviewing the plan DRWV does not believe that DRS provided concrete responses to the SRC’s recommendations. It would be helpful if DRS outlined specific timelines as it relates to the plan. For example, the language in the plan that addresses training does not specific how often DRS plans to provide training. 
WVDRS Response:
As this is a VR Portion of the WV Combined State Plan for Program Years 2024-2027, a specific timeline for certain activities covering the next four years would not be appropriate. However, WVDRS remains committed to conducting training and other activities as needed and appropriate. As a member of SRC, DRWV will remain informed of WVDRS' ongoing and planned activities.  

5. Provide the VR agency’s response to the Council’s input and recommendations, including an explanation for the rejection of any input and recommendations.
List each recommendation/input followed by the VR agency response
WVDRS Response to Observation/Recommendation 1:
WVDRS agrees with the benefits of collecting and utilizing data to assess the impact of Pre-ETS and VR services on the long-term success of students with disabilities.  WVDRS continues to expand and enhance partnerships at the state and local levels to ensure students with disabilities, and their families, are aware of the full range of services available through other agencies and programs.  Since the enactment of WIOA, WVDRS has continually expanded its Pre-ETS offerings through in-house and purchased services from CRPs and other community providers.  Many Pre-ETS providers incorporate presentations, resources, and materials from additional partners, including local employers, as part of their services.  WVDRS will continue to encourage this practice, whenever appropriate.
WVDRS Response to Observation/Recommendation 2:
WVDRS agrees that it is important for students and youth with disabilities to begin the vocational rehabilitation process as early as appropriate after reaching 14 years of age. WVDRS is open to the recommendation and has requested that counselors identify any possible opportunities for additional embedded VR offices within high schools. WVDRS continues to maintain an office on-campus at the WV Schools for the Deaf and Blind to provide awareness and services, including Pre-ETS, in an expeditious manner. If additional opportunities arise, WVDRS will move forward to establish offices, where appropriate and agreed upon by both parties. In support of this aim, WVDRS currently has 64 vocational rehabilitation counselors assigned to serve youth and students with disabilities, including a counselor assigned to each high school in the state. Thirty-seven counselors are assigned exclusively to transitioning youth territories, allowing for more time and resources to provide outreach and services, particularly Pre-ETS to high school students. These counselors are also beginning outreach to students in the ninth grade to ensure sufficient time to provide Pre-ETS and develop and implement a plan for the student’s transition from high school to postsecondary education, employment, or training. Additionally, WVDRS has made concerted efforts to provide outreach and services to nontraditional education settings for youth with disabilities, such as juvenile centers and facilities, Youth Reporting Centers, and other similar locations. The youth in these settings are afforded the same opportunity to receive Pre-ETS and other VR services as individuals in traditional settings, as appropriate. Further outreach continues to be conducted with stakeholder groups, such as parent and grandparent organizations, to include those students who may be in homeschool, private school, or other educational settings. For an example of the agency’s efforts to educate parents, WVDRS utilizes the West Virginia Parent Training and Information, Inc (WVPTI). The WVPTI is the only organization in West Virginia charged by the U.S. Department of Education/Office of Special Education Programs to serve as the state's Parent Training and Information Center. As mandated in the Individuals with Disabilities Education Act, the WVPTI provides parents of children with disabilities with the information and skills necessary to become effective partners in their children's provisions for special education and related services, including vocational rehabilitation services provided by WVDRS.
In 2021, the WVDRS developed the Systemic Transition Enhancement Project (STEP 21). The STEP 21 initiative encourages WVDRS consumers, WVDRS vocational rehabilitation counselors and other staff, WVDRS partners, and stakeholders to work harder together to increase coordination and cooperation to expand access and opportunities for individuals with disabilities, especially students with disabilities, to participate in and succeed in education and training programs that will lead to high-quality employment. Through STEP 21, WVDRS is also expanding coordination and outreach efforts with WVDRS partners including Special Education, Career Technical Education, local schools and their administrators, community service providers, and other partners to further enhance relationships and increase buy-in that will facilitate systemic change and a systematic approach to jointly support students with disabilities in maximizing their potential.
WVDRS Response to Observation/Recommendation 3:
WVDRS is in agreement with the benefits of materials that enhance the communication between individuals with disabilities and first responders.  The agency appreciates the research and examples provided by the SRC, CSAVR, and other VR agencies. WVDRS will work with its CACs, and other stakeholders including the SRC, to explore the development, creation, and distribution of materials that would afford more effective communication between first responders and people with disabilities statewide, as appropriate.
WVDRS Response to Observation/Recommendation 4:
WVDRS agrees that consumers are better served when additional partners are involved, whenever appropriate. WVDRS strives to continually enhance communication, awareness, and collaboration with partner agencies and stakeholders. As mandated by the Rehabilitation Act, as amended by WIOA, WVDRS provides individualized services to its consumers, as outlined in consumer IPEs. The IPE is the product of the informed choice of the consumer and VR counselor expertise. In addition to print materials, the agency’s websites, www.WVDRS.org and www.pathwayswv.org, provide descriptions of available services. The agency is currently in the process of developing a fully redesigned, accessible website that will allow for easier navigation, including information about available services. WVDRS will notify the SRC when the new site is ready for demonstration.
WVDRS Response to Observation/Recommendation 5:
WVDRS agrees with the value of partner conferences and other cross-training opportunities and will continue to coordinate with WV Combined State Plan partner agencies to share knowledge, information, and resources at the local, regional, and state levels.  As mentioned, WVDRS is present at AJCs across the state.  These co-locations allow for greater coordination among partner agencies to better serve individuals with disabilities. Data sharing with core WIOA partners, WorkForce WV and WV Adult Education, allow for enhanced and efficient service delivery for consumers who are co-enrolled across multiple programs, even when served through a non-AJC location. 
WVDRS Response to Observation/Recommendation 6:
WVDRS agrees with the importance of informing and coordinating with employers to better serve consumers and employees with disabilities. The agency will continue to highlight business success stories through a variety of methods, including recognition events, social media, and email blasts. WVDRS will also continue to actively participate in Chambers of Commerce meetings and events to enhance its relationship with businesses across the state. WVDRS supports and promotes WVABLE to its staff and consumers and appreciates the SRC having WVABLE as a presenter during a previous SRC meeting in 2023. WVABLE was also invited to attend its most recent conference to provide additional information to WVDRS staff.
WVDRS Response to Observation/Recommendation 7:
WVDRS agrees with the importance of ensuring public awareness of the VR program in West Virginia and will continue to utilize a variety of methods to conduct outreach. As evidenced by the substantial increase in the number of consumers over the last several years, from 6,326 in FY 2020 to 12,172 in FY 2023, West Virginians with disabilities are increasingly aware of WVDRS and its services.
WVDRS has further enhanced its outreach efforts to potentially underserved areas and populations across the state by adding a full-time position responsible for conducting outreach across the state to ensure individuals are aware of the vocational rehabilitation program in WV. Outreach strategies are developed based on information and data provided by the WVDRS State Plan and Program Evaluation Unit on unserved or underserved populations that are not currently participating in WVDRS services.
The role of the full-time position is to raise awareness and promote WVDRS services to individuals, communities, and organizations on a statewide level and to share information on a level that allows individuals to make an informed decision to seek WVDRS services when they are ready to enter the workforce. Strategies include presenting at conferences; partnering with clinics and recovery centers; and attending health fairs, school fairs, and other community events throughout West Virginia's 55 counties. WVDRS also continues conversations with mandated partners and state agencies as services change.
WVDRS’ primary messages include that we work with individuals with disabilities beginning at age 14 and through retirement; we provide career exploration services for students with disabilities, as well as Pre-ETS services; we promote quality employment outcomes in competitive integrated employment through STEP 21; and our service delivery system is set up to take advantage of additional services provided by partner agencies to maximize the benefits for consumers in the West Virginia workforce system.
WVDRS Response to Observation/Recommendation 8:
WVDRS agrees with the SRC regarding the importance of working with various councils, boards, and programs including Jobs and Hope. The members of the WVDRS Executive Management Group, as well as WVDRS Field Specialty Program staff, regularly participate in numerous meetings and events of partner councils, boards, government agencies and organizations, and other stakeholder groups as part of their ongoing job duties to represent WVDRS and promote WVDRS services and programs. WVDRS will continue to expand and enhance partnerships and participation, whenever and wherever possible. 
WVDRS Response to Observation/Recommendation 9:
WVDRS agrees that driving and transportation in general continue to be a barrier to employment for many West Virginians with disabilities of all ages. WVDRS continues to seek solutions to transportation issues and maintains this as an agency goal and priority. During the initial phase of the vocational rehabilitation process, WVDRS counselors discuss transportation-related issues with consumers. Counselors work with consumers to address and resolve any identified disability-related employment barriers; services to circumvent barriers are included in Individualized Plans for Employment and may include transportation services. WVDRS also emphasizes individualized transportation services, including driver training, bioptic training, vehicle modification, and vehicle purchase, when necessary. WVDRS agrees that counselors need to stay abreast of resources available to consumers with disabilities regarding driving licensure, including provisional licensure, in order to best meet their needs for necessary transportation related to employment. WVDRS will also continue to enhance transportation and other rehabilitation technology services through community-based providers, as needed and appropriate.
WVDRS Response to Observation/Recommendation 10:
WVDRS agrees that training conferences are extremely valuable for agency staff members. In the past, these conferences have provided expert speakers, training sessions, and networking opportunities for field staff from across the state. Additionally, it is an enriching experience for staff members to meet others from throughout West Virginia. The conference promotes cohesiveness among VR staff, as well as team building, in order to serve consumers with disabilities statewide. In 2023, WVDRS held a partner conference, a WVDRS staff training conference, and an in-person and virtual Ability Works Ceremony. The hybrid Ability Works ceremony allows for all WVDRS staff, and other stakeholders, to participate either live or view at their convenience. WVDRS intends to continue conferences and ceremonies of this nature in the future.
The agency has included former WVDRS consumers at various conferences and events, such as transition fairs, as speakers and panel members and agrees with the SRC regarding the powerful, beneficial impact they have on WVDRS staff and potential and current consumers.
THE DESIGNATED STATE UNIT’S EXPLANATIONS FOR REJECTING ANY OF THE COUNCIL’S INPUT OR RECOMMENDATIONS.
The agency is in agreement with the input and recommendations provided by the SRC. Please see the previous section for the full WVDRS responses to the SRC input and recommendations.
b. Comprehensive Statewide Needs Assessment (CSNA).
Section 101(a)(15), (17), and (23) of the Rehabilitation Act require VR agencies to provide an assessment of:
1. The VR services needs of individuals with disabilities residing within the State, including:
A. Individuals with the most significant disabilities and their need for Supported Employment;
To comply with provisions of Title I, Section 101, State Plans, of the Rehabilitation Act Amendments of 1998 and Section 721, State Plans, of the Rehabilitation Act as amended by the Workforce Innovation and Opportunity Act (WIOA), the West Virginia Division of Rehabilitation Services (WVDRS) and the West Virginia State Rehabilitation Council (WVSRC) conducted a three-year comprehensive statewide assessment of the vocational rehabilitation (VR) services needs of individuals with disabilities in West Virginia.  The CSNA was conducted in conjunction with full WVSRC, which was fully involved from inception to the reporting of the results.
While the findings of the 2024 CSNA also include individuals with most significant disabilities in all areas referring to individuals with significant disabilities, PY23 data indicates the most frequently provided services to individuals with the most significant disabilities receiving supported employment are assessments, diagnosis and treatment of impairments, job readiness training, on-the-job supports, transportation, and maintenance (direct reimbursement to consumers). A recent survey of WVDRS counselors serving individuals under an individualized plan for supported employment indicates the greatest need for providing supported employment services to consumers with the most significant disabilities is additional vendors in certain areas of West Virginia to provide the services. To address this problem, WVDRS employs two specially trained employees to meet the training needs for new CRPs and existing CRP staff. To meet the needs of underserved areas and rural communities, WVDRS encourages CRPs to offer and provide services on a statewide basis. Any CRP, acknowledged by WVDRS as a vendor, can provide services to consumers anywhere in West Virginia, if they choose. WVDRS also recognizes the difficulty in finding suitable placement opportunities for people with disabilities, including those with MSD, and we utilize our team of employment specialists to connect with employers and develop relationships to create job opportunities, especially in rural communities.
Four major objectives of the comprehensive statewide needs assessment study included examination of the rehabilitation needs of: (1) individuals with significant and most significant disabilities, including their needs for supported employment services; (2) individuals with disabilities who are minorities and individuals with disabilities who have been unserved or underserved by the VR program; (3) individuals with disabilities served through other components of the statewide workforce development system; and (4) youth with disabilities, and students with disabilities, including their need for pre-employment transition services or other transition services. The role of community rehabilitation programs (CRPs) as service providers was reviewed to address the need to establish, develop, or improve CRPs in West Virginia.
To maintain effective and comprehensive service delivery programs for West Virginians with disabilities, the needs assessment identified various service needs of individuals with significant and most significant disabilities. Some needed services such as transportation, housing, and personal assistance are beyond the scope of the state VR program and thus, require coordination and cooperation among a diverse range of public and private agencies and other organizations serving West Virginians with disabilities. In addition to consumer input, the needs assessment recognized the service providers’ perceptions of the needs of consumers with disabilities, including rehabilitation services associates, counselors, supervisors and managers of WVDRS, CRPs, and Workforce Development Board members throughout West Virginia.
THE STATEWIDE NEEDS ASSESSMENT OF CONSUMERS WITH SIGNIFICANT DISABILITIES RESULTS OF THE ANALYSIS OF THE REPORTED SERVICE NEEDS OF PERSONS WITH SIGNIFICANT DISABILITIES
To identify the service needs of consumers with significant disabilities, the State Plan and Program Evaluation (SPPE) Unit of WVDRS used the same, valid method utilized for the FY 2021 CSNA. At WVDRS, as part of the intake process for VR services, a question regarding service needs was posed to potential consumers at the time of application. The reported service needs (hereafter called needs comments) were then recorded in the WVDRS electronic case management system (iECM). In 2023, using data from iECM, SPPE staff members conducted a qualitative analysis of the needs comments of 1,209 persons with significant disabilities of various age and disability groups statewide in pre-service statuses. These individuals represent a good sample of consumers with significant disabilities that will continue to seek assistance from agencies in coming years, ceteris paribus. The qualitative analysis of the needs comments of persons with significant disabilities included 1,209 statewide applicants with significant disabilities across all WVDRS districts. All 55 counties in West Virginia were represented in the sample and the sample resembles population proportions, by county. Also included in the sample were the expressed VR service needs across the state of transitioning youth (aged 24 years or under) with significant disabilities (including students with disabilities), consumers with significant disabilities from minority backgrounds, and consumers with significant disabilities aged 65 years or older.
SPPE staff members conducted a qualitative analysis of the needs comments of the 1,209 consumers. The needs comments were analyzed and grouped into one or more of five general themes: Education, Training, Health, Employment/CRP, and Support. Needs comments were further sub-grouped by more specific types of service (e.g., Life Skills Training, Job Placement, Hearing/Audiological Service, etc.). Additionally, the needs comments of a subset of 568 students with disabilities were analyzed separately and grouped into one or more of six categories of Pre-Employment Transition Services (Pre-ETS): Job Exploration Counseling, Work-Based Learning Experiences, Counseling on Postsecondary Opportunities, Workplace Readiness Training, Instruction in Self-Advocacy, and General Pre-ETS.
The following report presents the results of the qualitative analysis on the needs comments of these 1,209 consumers. Results will first be presented regarding the entire sample of consumers with significant disabilities. This will be followed by results regarding transitioning youth with significant disabilities, consumers with significant disabilities from minority backgrounds, and consumers with significant disabilities aged 65 years or older. Finally, the Pre-ETS needs of students with disabilities will be discussed.
Findings – Consumers with Significant Disabilities
The demographics profile of these individuals with significant disabilities consists of the following characteristics:
- Gender: 48.6% male, 51.1% female, 0.2% did not self-identify;
 - Race: 89.8% White, 9.8% Other (African American/Hispanic Latino/American Indian or Alaska Native/Asian/Pacific Islander), 0.3% Unspecified;
- Age: 56.9% under 22 years old, 16.4% 22-34 years, 9.2% 35-44 years, 14.0% 45-64 years, 3.6% 65 years or older;
- Primary Impairment: 7.8% Sensory/Communicative Impairments (including blindness, other visual impairments, deafness – primary communication visual, deafness – primary communication auditory, hearing loss – primary communication visual, hearing loss – primary communication auditory, other hearing impairments, deaf-blindness, and communicative impairments), 13.9% Physical Impairments (including mobility orthopedic/neurological impairments, manipulation/dexterity orthopedic/neurological impairments, both mobility and manipulation/dexterity orthopedic/neurological impairments, other orthopedic impairments, respiratory impairments, general physical debilitation, and other physical impairments), 78.2% Mental Impairments (including cognitive impairments, psychosocial impairments, and other mental impairments);
- Referral Source: 1.0% Adult Education and Literacy Programs, 0.1% Centers for Independent Living, 0.2% Child Protective Services, 2.3% Community Rehabilitation Programs, 0.9% Consumer Organizations or Advocacy Groups, 0.1% Corrections/Other, 0.3% DOL Employment and Training Service Programs, 30.9% Educational Institutions (elementary/secondary), 6.2% Educational Institutions (postsecondary), 0.5% Employers, 0.1% Faith-Based Organizations, 18.8% Family/Friends, 0.3% Intellectual and Developmental Disabilities Providers, 0.3% Jobs and Hope, 0.1% Juvenile Justice, 3.9% Medical Health Provider (Public or Private), 3.9% Mental Health Provider (Public or Private), 0.7% One-stop Employment/Training Centers, 1.2% Other State Agencies, 0.3% Other VR State Agencies, 0.2% Other WIOA-funded Programs, 0.2% Public Housing Authority, 23.3% Self-referral, 0.1% Social Security Administration (Disability Determination Service or District Office), 0.2% Veteran’s Administration, 0.6% Welfare Agency (State or local government), 3.3% Other Sources;
- Employment Status at Application: 16.5% Employed, 83.5% Employment not reported;
- Primary Source of Support: 18.5% Personal Income, 65.6% Family and Friends, 13.2% Public Support (SSI, SSDI, TANF, etc.), 2.4% Other (Private disability insurance, Private charities).
Service Needs Reported by Consumers with Significant Disabilities Education
Education needs were identified by 305 (25.2%) of the needs comments. Of these 305, education needs identified were categorized as transition (47.2%), 2-year or 4-year college (36.4%), other (11.5%), graduate degree education (3.3%), high school education (3.0%), accommodations (3.0%), vocational education (2.6%), tutoring (2.3%), assessments (1.0%), and adult basic education (0.3%). 
The numbers add up to more than 100% because consumers utilized more than education service.
Most Frequently Reported Education Needs
Transition (47.2%)
Nearly half of the consumers with expressed education needs indicated a need for transition services. This was generally indicated with phrases such as “assistance with transition” or “help with transitioning after high school.”
2-year or 4-yearCollege (36.4%)
Many of the consumers with significant disabilities who expressed needs regarding education were particularly interested in attending and completing college. While some needs comments were rather general (e.g., “help going to college”) others were relatively specific, indicating a particular school of interest or a particular major.
Other (11.5%)
This category included responses by consumers with significant disabilities who indicated a need for education, or assistance with education, but were not much more specific than that. A typical need comment in this category may have included phrases such as “help with continuing my education,” or “assistance with school.”
Training
Training needs were identified with 442 (36.6%) of the needs comments. Of these 442, training needs identified were categorized as business/vocational training (86.2%), drive training/licensing (12.0%), job search training/assistance (5.2%), other (1.8%), and independent living skills (0.5%). 
The numbers add up to more than 100% because consumers utilized more than one training service.
Most Frequently Reported Training Needs
Business/Vocational Training (86.2%)
By far, the most identified training need was training for employment. Within this category, responses varied from the general (e.g., “seeking assistance with training”) to the rather specific (e.g., “…wants to obtain her phlebotomy certificate from Med-Care”).
Drive Training/Licensing (12.0%)
Several consumers with significant disabilities identified the need for driving skills or legal driving capability. This was referred to in a number of ways, including “driver’s training,” “driver’s license,” or “learner’s permit.” CDL training was also included in this category.
Job Search Training/Assistance (5.2%)
Some consumers with significant disabilities identified the need for assistance with job searching. This was referred to as either “job search assistance” specifically, or something akin to the term, such as “…help with finding employment….”
Health
Health needs were identified by 138 (11.4%) of the needs comments. Of these 138, health needs identified were categorized as hearing/audiological services (50.7%), psychological/psychiatric (32.6%), eye care (8.7%), other (7.2%), physician’s services (2.9%), dental care (1.4%), hospital services (1.4%), and speech/communication therapy (0.7%).
Most Frequently Reported Health Needs
Hearing/Audiological Services (50.7%)
The most common health needs for consumers with significant disabilities were related to hearing. Most of these needs comments specifically stated the need for hearing aids.
 Psychological/Psychiatric (32.6%)
Needs comments in this category indicated the need for mental health services of some type. However, the specific need varied. Some consumers with significant disabilities simply expressed the need for “therapy” or “counseling,” while others were interested in treatment for specific diagnoses, such as ADHD or anxiety.
Eye Care (8.7%)
Some needs comments indicated the need for eye care services. The verbiage for this need varied, as indicated by phrases such as “…needing a pair of glasses,” “help with low vision,” and “rapidly deteriorating vision.”
Other (7.2%)
Needs comments in this category indicated the need for health services of some type that did not fit well in another category. This varied from the general (e.g., “physical restoration”) to the somewhat specific (e.g., “help with prosthesis”).
Employment/CRP
Employment/CRP service needs were the most frequently identified, noted in 61.2% of the needs comments. Of these 740, employment/CRP service needs identified were categorized as job placement (71.6%), vocational counseling and guidance (21.6%), job retention (6.5%), other (5.0%), life skills training (1.9%), work-related tools or equipment (1.8%), supported employment (SE) (1.2%), community-based assessment (CBA) (0.4%), small business development (0.4%), worksite modification or accommodation (0.3%), psychological evaluation (0.3%), job coaching other than SE (0.3%), work skills assessment (0.1%), vocational evaluation (0.1%), and work adjustment training (0.1%).
Most Frequently Reported Employment/CRP Needs
Job Placement (71.6%)
A large portion of consumers with significant disabilities were primarily interested in finding a job. Many of these consumers with significant disabilities simply needed placement in a job, already having the requisite skills and abilities to work. Needs comments that specifically included the word “placement” fit into this category. However, many may have stated the need to “find work” or “find a job.” Some consumers with significant disabilities expressed an interest in a specific occupation or field of work, such as “…work with animals” or “…employment driving a truck.”
Vocational Counseling and Guidance (21.6%)
Some consumers with significant disabilities indicated a need for vocational counseling and guidance. Key phrases in this category include “vocational counseling,” “job exploration,” and “planning a vocational goal.”
Job Retention (6.5%)
Some consumers with significant disabilities expressed interest in keeping the job they already had. This was frequently tied to the acquisition of hearing aids, but not necessarily. Key phrases in this category included “job retention” and “maintain employment,” among others.
Other (5.0%)
Some consumers with significant disabilities indicated a need for services related to employment, but the need indicated was either too general to be classified (e.g., “CRP services”) or otherwise didn’t fit in one of the sub-categories (e.g., “acquiring certifications”).
Support
Support needs were identified by 214 (17.7%) of the 1,209 consumers. Of these 214, support needs identified were categorized as financial assistance (82.2%), assistive technology (6.5%), orientation/mobility services (3.7%), housing assistance (2.3%), other (2.3%), vehicle modification (1.9%), home modification (1.0%), transportation (1.0%), assistive devices (0.5%), and vehicle maintenance/repair (0.5%).
The numbers add up to more than 100% because consumers utilized more than one support service.
Most Frequently Reported Support Needs
Financial Assistance (82.2%)
Most consumers with significant disabilities identified the need for financial assistance, usually for hearing aids, education, or other training. Key words and phrases for this category include “help with tuition,” “sponsorship,” and “purchase of hearing aids,” among others.
Assistive Technology (6.5%)
Some consumers with significant disabilities identified the need for assistive technology. This need was sometimes acknowledged simply as “assistive technology” or “rehab tech,” but was occasionally referred to more specifically (e.g., “…help with technology to help him drive”).
Findings – Transitioning Youth with Significant Disabilities
Of the statewide total of 1,209 persons with significant disabilities at the time of their WVDRS application, 757 persons (62.6%) were determined to be of transition status (age 24 and under). The demographic profile of this subset of transition status individuals with significant disabilities consists of the following characteristics:
- Gender: 50.3% male, 49.3% female, 0.4% did not specify;
- Race: 88.6% White, 11.1% Other (African American/Hispanic Latino/American Indian or Alaska Native/Asian/Pacific Islander), 0.3% Unspecified;
- Age: 79.4% under 20 years old, 20.6% 20-34 years;
- Primary Impairment: 4.1% Sensory/Communicative Impairments (including blindness, other visual impairments, deafness – primary communication visual, deafness – primary communication auditory, hearing loss – primary communication visual, hearing loss – primary communication auditory, other hearing impairments, deaf-blindness, and communicative impairments), 10.2% Physical Impairments (including mobility orthopedic/neurological impairments, manipulation/dexterity orthopedic/neurological impairments, both mobility and manipulation/dexterity orthopedic/neurological impairments, other orthopedic impairments, respiratory impairments, general physical debilitation, and other physical impairments), 85.5% Mental Impairments (including cognitive impairments, psychosocial impairments, and other mental impairments);
- Referral Source: 0.9% Adult Education and Literacy Programs, 0.3% Child Protective Services, 1.2% Community Rehabilitation Programs, 0.8% Consumer Organizations or Advocacy Groups, 48.9% Educational Institutions (elementary/secondary), 7.4% Educational Institutions (postsecondary), 0.1% Faith-Based Organizations, 18.9% Family/Friends, 0.4% Intellectual and Developmental Disabilities Providers, 1.3% Medical Health Provider (Public or Private), 2.0% Mental Health Provider (Public or Private), 0.4% One-stop Employment/Training Centers, 1.8% Other Sources, 0.3% Other State Agencies, 0.1% Other VR State Agencies, 0.1% Other WIOA-funded Programs, 0.1% Public Housing Authority, 14.4% Self-referral, 0.4% Welfare Agency (State or local government);
- Employment Status at Application: 4.7% Employed, 95.3% Employment not reported;
- Primary Source of Support: 5.8% Personal Income, 86.8% Family and Friends, 5.9% Public Support (SSI, SSDI, TANF, etc.), 1.3% Other (Private disability insurance, Private charities).
Service Needs Reported by Transitioning Youth with Significant Disabilities
Education
Education needs were identified in 263 (34.7%) of the needs comments of transitioning youth with significant disabilities. Of these 263, education needs identified were categorized as transition (54.8%), 2-year or 4-year college (37.6%), other (8.0%), accommodations (2.7%), vocational education (2.3%), tutoring (2.3%), high school education (1.5%), assessments (1.1%), graduate education (0.8%), and adult basic education (0.4%).
The numbers add up to more than 100% because consumers utilized more than one education service.
Most Frequently Reported Education Needs
Transition (54.8%)
Most responses by transitioning youth with significant disabilities indicated a need for transition from school to work. These comments included phrases such as “help with transitioning after high school” or “assistance with transition services.”
2-year or 4-year College (37.6%)
Several of the transitioning youth with significant disabilities who expressed needs regarding education were interested in attending and completing college. Many of these needs comments were general (e.g., “help going to college”), but some others were specific, indicating a particular school of interest or a particular major.
Other (8.0%)
Some responses by transitioning youth with significant disabilities indicated a need for education, or assistance with education, but were not much more specific than that. A typical response in this manner may have included phrases such as “help with school” or “educational services.”
Training
Among transitioning youth with significant disabilities, 324 of 757 (42.8%) needs comments involved training. Of these 324, training needs identified were categorized as business/vocational training (86.7%), drive training/licensing (11.7%), job search training/assistance (4.6%), other (2.1%), and independent living skills (0.3%).
The numbers add up to more than 100% because consumers utilized more than one training service.
Most Frequently Reported Training Needs
Business/Vocational Training (86.7%)
The most identified training need by transitioning youth with significant disabilities, by a substantial margin, was training for employment. Within this category, responses varied from the general (e.g., “training services”) to the specific (e.g., “phlebotomy program at Med Care”).
Drive Training/Licensing (11.7%)
Some transitioning youth with significant disabilities identified the need for driving skills or legal driving capability. This was referred to in a number of ways, including “driver’s license,” “driver’s training,” or “learner’s permit.” CDL training was also included in this category.
Health
Among transitioning youth with significant disabilities, 45 of 757 (5.9%) needs comments involved health. Of these 45, health needs identified were categorized as psychological/psychiatric (68.9%), hearing/audiological services (20.0%), eye care (4.4%), physician’s services (2.2%), hospital services (2.2%), and other (2.2%).
Most Frequently Reported Health Needs
Psychological/Psychiatric (68.9%)
Needs comments in this category indicated the need for mental health services of some type. However, the specific need varied. Some transitioning youth with significant disabilities expressed the need for “therapy,” “counseling,” or “mental restoration,” while others were interested in psychological evaluations.
Hearing/Audiological Services (20.0%)
Some of the health needs comments by transitioning youth with significant disabilities were related to hearing. Most of these needs comments specifically stated the need for hearing aids.
Employment/CRP
Among transitioning youth with significant disabilities, 448 of 757 (59.2%) needs comments involved employment/CRP services. Of these 448, employment/CRP service needs identified were categorized as job placement (75.0%), vocational counseling and guidance (27.9%), other (5.1%), life skills training (1.6%), work-related tools or equipment (1.6%), supported employment (SE) (0.7%), job retention (0.4%), vocational evaluation (0.2%), psychological evaluation (0.2%), community-based assessment (0.2%), work skills assessment (0.2%), and job coaching other than SE (0.2%).
The numbers add up to more than 100% because consumers utilized more than one employment/CRP service.
Most Frequently Reported Employment/CRP Needs
Job Placement (75.0%)
A large percentage of transitioning youth with significant disabilities were primarily interested in placement in a job. Needs comments that specifically included the word “placement” fit into this category. However, many stated the need for “work” or “employment.”
Vocational Counseling and Guidance (27.9%)
Some transitioning youth with significant disabilities indicated a need for vocational counseling and guidance. Key phrases in this category include “vocational counseling and guidance,” “career exploration,” and “planning a vocational goal.”
Other (5.1%)
Some transitioning youth with significant disabilities indicated a need for services related to employment, but the need indicated was either too general to be classified (e.g., “vocational services”) or otherwise didn’t fit in one of the sub-categories (e.g., “interview skills”).
Support
Among transitioning youth with significant disabilities, 11.4% of 757 needs comments involved support. Of these, support needs identified were categorized as financial assistance (88.4%), assistive technology services (5.8%), other (3.5%), housing assistance (1.2%), and orientation/mobility services (1.2%).
Most Frequently Reported Support Needs
Financial Assistance (88.4%)
Many transitioning youth with significant disabilities identified the need for financial assistance, usually for education or other training. Key words and phrases for this category include “assistance with educational expenses,” “sponsorship,” and “tuition assistance,” among others.
Assistive Technology Services (5.8%)
Some transitioning youth with significant disabilities identified the need for assistive technology. These needs comments specifically indicated “assistive technology” or “AT.”
Findings – Consumers with Significant Disabilities Aged 65 Years or Older
Of the statewide total of 1,209 persons with significant disabilities at the time of their WVDRS application, 43 persons (3.6%) were determined to be aged 65 years or older. The demographic profile of this subset of individuals with significant disabilities aged 65 years or older consists of the following characteristics:
 - Gender: 58.1% male, 41.9% female;
- Race: 90.7% White, 9.3% Other (African American/Hispanic Latino/American Indian or Alaska Native/Asian/Pacific Islander);
- Age: 100% 65 years or older;
- Primary Impairment: 63.6% Sensory/Communicative Impairments (including blindness, other visual impairments, deafness – primary communication visual, deafness – primary communication auditory, hearing loss – primary communication visual, hearing loss – primary communication auditory, other hearing impairments, deaf-blindness, and communicative impairments), 9.1% Physical Impairments (including mobility orthopedic/neurological impairments, manipulation/dexterity orthopedic/neurological impairments, both mobility and manipulation/dexterity orthopedic/neurological impairments, other orthopedic impairments, respiratory impairments, general physical debilitation, and other physical impairments), 27.3% Mental Impairments (including cognitive impairments, psychosocial impairments, and other mental impairments);
- Referral Source: 2.3% Community Rehabilitation Programs, 2.3% DOL Employment and Training Service Programs, 2.3% Educational Institutions (postsecondary), 2.3% Employers, 18.6% Family/Friends, 16.3% Medical Health Provider (Public or Private), 4.7% Other State Agencies, 2.3% Other VR State Agencies, 34.9% Self-referral, 14.0% Other Sources;
- Employment Status at Application: 60.5% Employed, 39.5% Employment not reported;
- Primary Source of Support: 58.1% Personal Income, 9.3% Family and Friends, 27.9% Public Support (SSI, SSDI, TANF, etc.), 4.6% Other (Private disability insurance, Private charities).
Service Needs Reported by Consumers with Significant Disabilities Aged 65 Years or Older
Education
Among consumers with significant disabilities aged 65 years or older, 2.3% of needs comments involved education (tutoring).
Training
Among consumers with significant disabilities aged 65 years or older, 4.7% of needs comments involved training (business/vocational training; drive training/licensing).
Health
Among consumers with significant disabilities aged 65 years or older, 72.1% of needs comments involved health. Health needs identified were categorized as hearing/audiological services (90.3%), other (6.5%), eye care (3.2%), and psychological/psychiatric (3.2%).
Most Frequently Reported Health Needs
Hearing/Audiological Services (90.3%)
Most consumers with significant disabilities aged 65 or older identified needs related to hearing. Most of these needs comments specifically stated the need for hearing aids.
Employment/CRP
Among consumers with significant disabilities aged 65 years or older, 44.2% of needs comments involved employment/CRP services. Employment/CRP service needs identified were categorized as job retention (52.6%) and job placement (47.4%).
Most Frequently Reported Employment/CRP Needs
Job Retention (52.6%)
Some consumers with significant disabilities aged 65 years or older expressed interest in keeping the job they already had. This was usually tied to the acquisition of hearing aids, but not necessarily. Key phrases in this category included “job retention” and “maintain employment.”
Job Placement (47.4%)
Some consumers with significant disabilities aged 65 years or older were primarily interested in finding a job. Their needs comments included a variety of phrases, including “job placement,” “help going to work,” and “wants to work.”
Support
Among consumers with significant disabilities aged 65 years or older, 44.2% of needs comments involved support.  Support needs identified were categorized as assistive technology (10.5%), financial assistance (78.9%) and orientation/mobility services (10.5%).
Most Frequently Reported Support Needs
Financial Assistance (78.9%)
Many consumers with significant disabilities aged 65 years or older identified the need for financial assistance. This was typically for hearing aids, but a couple of consumers requested financial assistance for higher education costs. Key words and phrases for this category include “sponsorship” and “financial assistance.”
Pre-Employment Transition Services
Pursuant to the Rehabilitation Act, as amended by WIOA, VR agencies are mandated to provide for the delivery of Pre-Employment Transition Services (Pre-ETS) to students with disabilities. As part of the CSNA, agencies are required to assess the needs of students with disabilities, including their need for Pre-ETS. To meet this requirement, WVDRS’ SPPE Unit analyzed the needs comments of a subset of students with disabilities to assess their need for the five required Pre-ETS activities: 1) Job Exploration Counseling, 2) Work-Based Learning Experiences, 3) Counseling on Postsecondary Opportunities, 4) Workplace Readiness Training, and 5) Instruction in Self-Advocacy. Additionally, needs comments that expressed a need for Pre-ETS without identifying a specific type of activity were grouped separately as “General Pre-ETS.”
Findings – Pre-ETS needs of Students with Disabilities
Of the statewide total of 1,209 persons with significant disabilities at the time of their WVDRS application, 568 persons (47.0%) were determined to be students. The demographic profile of this subset of individuals with significant disabilities who are students consists of the following characteristics:
- Gender: 51.9% male, 47.5% female, 0.5% did not self-identify;
- Race: 89.8% White, 10.2% Other (African American/Hispanic Latino/American Indian or Alaska Native/Asian/Pacific Islander);
- Age: 93.7% under 20 years old, 6.3% 20-34 years;
- Primary Impairment: 3.7% Sensory/Communicative Impairments (including blindness, other visual impairments, deafness – primary communication visual, deafness – primary communication auditory, hearing loss – primary communication visual, hearing loss – primary communication auditory, other hearing impairments, deaf-blindness, and communicative impairments), 11.3% Physical Impairments (including mobility orthopedic/neurological impairments, manipulation/dexterity orthopedic/neurological impairments, both mobility and manipulation/dexterity orthopedic/neurological impairments, other orthopedic impairments, respiratory impairments, general physical debilitation, and other physical impairments), 85.0% Mental Impairments (including cognitive impairments, psychosocial impairments, and other mental impairments);
- Referral Source: 0.5% Adult education and Literacy Programs, 0.4% Child Protective Services, 0.7% Community Rehabilitation Programs, 1.1% Consumer Organizations or Advocacy Groups, 62.0% Educational Institutions (elementary/secondary), 6.5% Educational Institutions (postsecondary), 0.2% Faith-Based Organizations, 13.9% Family/Friends, 0.2% Intellectual and Developmental Disabilities Providers, 1.2% Medical Health Provider (Public or Private), 0.9% Mental Health Provider (Public or Private), 0.2% Other WIOA-funded Programs, 10.6% Self-referral, 1.8% Other Sources;
- Employment Status at Application: 1.4% Employed, 98.6% Employment not reported;
- Primary Source of Support: 3.9% Personal Income, 91.2% Family and Friends, 4.0% Public Support (SSI, SSDI, TANF, etc.), 0.9% Other (Private disability insurance, Private charities).
Pre-ETS Needs Reported by Students with Disabilities
Among students with disabilities, 241 of 568 (42.4%) needs comments indicated the need for Pre-ETS. These 241 comments either addressed Pre-ETS in general terms or addressed a specific type of Pre-Employment Transition Service.
Job Exploration Counseling
Among students with disabilities indicating the need for Pre-ETS, 47.7% of needs comments involved job exploration counseling, the most requested Pre-ETS category. These comments included key words and phrases such as “career exploration,” “job exploration,” and “vocational counseling and guidance,” among others.
Work-Based Learning Experiences
Among students with disabilities indicating the need for Pre-ETS, 8.7% of needs comments involved work-based learning experiences. These comments typically included phrases like, “work-based learning” and “work experience.”
Counseling on Postsecondary Opportunities
Among students with disabilities indicating the need for Pre-ETS, 28.2% of needs comments involved counseling on postsecondary opportunities. These comments included a variety of key words and phrases, such as, “postsecondary education” and “help with transition to college.”
Workplace Readiness Training
Among students with disabilities indicating the need for Pre-ETS, 12.9% of needs comments involved workplace readiness training. These comments expressed the need for “help preparing for work,” “employment readiness,” “workplace readiness,” and other similar ideas.
Instruction in Self-Advocacy
Among students with disabilities indicating the need for Pre-ETS, 8.3% of needs comments involved instruction in self-advocacy. These comments typically included the phrase “self-advocacy” specifically.
General Pre-ETS
Among students with disabilities indicating the need for Pre-ETS, 32.8% of needs comments involved a general need for Pre-Employment Transition Services, either without specifying a type of service, or while additionally specifying a particular service. These comments usually included key words and phrases such as, “Pre-ETS” or “Pre-Employment Transition.” Additionally, some comments referred to summer programs, indicating desire for the Career Exploration Opportunity Summit conducted by WVDRS that provides Pre-ETS to high school students during a week-long summer internship.
RESULTS OF THE SURVEY OF WVDRS FIELD STAFF ON THE NEEDS OF PERSONS WITH SIGNIFICANT DISABILITIES
To comply with provisions of the Workforce Innovation and Opportunity Act, the West Virginia Division of Rehabilitation Services (WVDRS) must conduct a triennial comprehensive statewide assessment (CSNA) of the vocational rehabilitation (VR) service needs of individuals with disabilities in West Virginia. Major objectives of the comprehensive statewide needs assessment (CSNA) study include examination of the rehabilitation needs of 1) individuals with significant and most significant disabilities, including their needs for supported employment services, 2) individuals with disabilities who are minorities and individuals with disabilities who have been unserved or underserved by the VR program, 3) individuals with disabilities served through other components of the statewide workforce investment system, and 4) youth with disabilities (24 years old and younger), and students with disabilities (14-21 years old and enrolled in an education/training program), including their need for pre-employment transition services (Pre- ETS). The role of community rehabilitation programs (CRPs) as service providers is also reviewed to address the need to establish, develop, or improve CRPs in West Virginia.  The CSNA also requires the agency to work with employers to identify competitive integrated employment and career exploration opportunities.
The CSNA includes input from WVDRS field staff (District Managers, Branch Office Managers, Supervisors, VR Counselors, and Rehabilitation Services Associates) on the service needs and service gaps of their consumers.  Given that field staff interact directly with WVDRS consumers, they are a key resource on the service needs and service gaps in specific service areas statewide.  Analysis will provide insight into service needs and gaps, from a statewide perspective down to district, branch office, and counselor territory levels.  This will assist WVDRS in making appropriate, targeted, and effective data-driven decisions.
Method
The State Plan and Program Evaluation (SPPE) Unit developed a multiple-choice and open-ended response survey for WVDRS field staff to provide feedback on the service needs and service gaps of their consumers.  An online survey was developed, and links were distributed to field staff for them to complete the survey.
Field staff were given approximately a month for survey completion and were told to contact SPPE Unit staff with any questions regarding the survey. 
Respondent Information
The survey collected information about the respondent for use in data analyses and to assist WVDRS in making targeted and necessary changes based on the service needs and service gaps by office and district. 
Respondents were asked to provide information about their primary caseload by selecting from: General Field, Blind/Visually Impaired, School/Transition, Deaf/Hearing Impairment.  Respondents could select ‘Other’ and write in a caseload not listed.
Respondents were asked to provide their WVDRS office location(s) and which county or counties in the state they covered.
Respondents were asked to provide the number of years they have worked in field services and to indicate job titles they have held at WVDRS by selecting from the following: Rehabilitation Counselor Trainee, Rehabilitation Counselor, Senior Rehabilitation Counselor, Certified Rehabilitation Counselor, Branch Office Manager/Supervisor, District Manager, or Rehabilitation Services Associate.  Respondents were also given an option for “Other” and write in their job title if not listed. 
Assessing Service Needs and Service Gaps
The main objective of the survey was to assess the service needs and service gaps for WVDRS consumers with significant or most significant disabilities.  Seventy-one services were placed into six categories: Educational, Training, Health, Employment and CRP, Support, and Pre-Employment Transition Services (Pre-ETS).  Each service was accompanied by checkboxes in two columns: Needed and Gap. Respondents were asked to “For each item, please indicate (in the Needed column) whether most of the consumers you serve in your area can benefit from the service.” Additionally, respondents were asked to “indicate if you feel there is a service gap (i.e., services are needed, but not sufficiently available) for each service by checking the Gap column.”
Services from the survey are listed below by category:
Educational Services— 2-year or 4-year College, Adult Basic Education, Graduate Degree Education, High School Education, Literacy Instruction, Special Education, Tutoring, and Vocational Education
Training Services— Business/Vocational Training, Career Planning Training, Disability Rights Training, Driver Training, Independent Living Skills, Job Club Training, Job Search Training, Lip Reading, On-the-Job Training, Reading in Braille, Sign Language, Work Adjustment Training
Health Services— Dental Care, Eye Care, Hearing/Auditory Services, Hospital Services, Occupational Therapy, Physical Therapy, Physician's Services, Psychological/Psychiatric Treatment, Speech/Communication Therapy, and Substance Abuse Treatment.
Employment and CRP Services— Community-Based Assessment, Direct Placement by CRPs, Extended Assessment, Extended Supported Employment Service (ESES), Job Coaching Other than SE, Job Development, Job Placement, Labor Market Information, Psychological Evaluation, Small Business Development, Supported Employment (SE), Trial Work Experience, Vocational Counseling and Guidance, Vocational Evaluation, Work Adjustment Training, Worksite Modification or Accommodation, Work-related Tools or Equipment, and Work Skills Assessment.
Support Services— Assistive Devices (e.g., cane, wheelchair), Assistive Technology Devices, Childcare, Family Services, Financial Assistance, Home Modification, Housing Assistance, Interpreter Services, Orientation/Mobility Services, Peer Support, Personal Assistant/Attendant Services, Post-Employment Services (follow-up), Reader Services, Transportation, Vehicle Maintenance/Repair, and Vehicle Modification.
Pre-Employment Transition Services— Counseling on Postsecondary Opportunities, Job Exploration Counseling, Self-Advocacy Training, Work-Based Learning Experiences, and Workplace Readiness Training.
Overall Service Needs for WVDRS Consumers
The survey included five questions where respondents were asked to list UP TO FIVE services that consumers need in their service area.  The question was repeated for 1) consumers with disabilities in WVDRS general territories, 2) transitioning youth with disabilities (age 24 and younger), 3) individuals who are deaf/hearing impaired, 4) individuals who are blind/visually impaired, and 5) minority individuals with disabilities.  Respondents were also asked to indicate if they did not have experience working with consumers described in each question.
Barriers to Employment
Respondents were asked to indicate whether any of the following are substantial barriers, preventing the consumers you serve from gaining and/or maintaining employment.”
Respondents were provided a list of the following 28 potential barriers: 
•	Adequate Housing
•	Childcare
•	Consumer Attitudes
•	Displaced Homemaker
•	Employer Attitudes
•	Ex-Offender
•	Exhausted TANF
•	Family Support
•	Foster Care
•	Homeless/Runaway
•	Illiteracy
•	Inadequate Medical Care and/or Medical Insurance
•	Lack of Available Services from CRPs
•	Lack of Disability Benefits and/or Food Assistance
•	Lack of Information Regarding Disability Resources
•	Lack of Long-Term Support after Job Placement
•	Lack of Personal Care Attendant Services
•	Lack of Physical Access to Employer or Services (e.g., ramps, etc.)
•	Lack of Time Spent with VR Counselor
•	Limited English
•	Long-term Unemployment
•	Low Income
•	Migrant/Seasonal Worker
•	Single Parent
•	Slow Job Market
•	Transportation
•	WVDRS Budget Restriction
Space was provided to write in and rate any additional barriers not found on the list, if needed.
Integration with Core Partners
The survey included four open-ended response questions regarding respondents’ familiarity, experience, and recommendations on integrating services with Workforce Development System Core Partners of WorkForce WV and WV Adult Education:
1)          Please describe your familiarity with the services that WorkForce WV and WV Adult Education provide.
2)          Please describe the level of need that our consumers with significant disabilities have for services that WorkForce WV and WV Adult Education provide.
3)          Please comment on your experiences with integrating service (not including referrals) with WorkForce WV and WV Adult Education (e.g., using Labor Market Information, co-serving a client with Adult Education). In addition to your experiences, please discuss other activities that WVDRS could conduct with our core partners to further help our consumers with significant disabilities.
4)          Please provide recommendations on how to better facilitate our partnerships with WorkForce WV and WV Adult Education (e.g., specific cross-trainings, co-location, etc.).
Other Comments
The survey concluded with three open-ended response questions: 1) “What can WVDRS provide you to better serve our consumers and help you perform your job more effectively?”, 2) “Based on your experience, what services can WVDRS provide to employers to increase employment of individuals with significant disabilities?”, and 3) “Please provide any additional comments regarding unmet service needs of individuals with significant or most significant disabilities with whom you work.”
Results
Results are based on 186 surveys that were completed by WVDRS field staff.
Respondent Information
Primary Caseload
General Field caseloads were reported as the primary caseload by 76 respondents (49.4% of 154 people who responded to this question), while 77 (50%) reported a primary caseload of School/Transition.  Fourteen (9.1%) reported Blind/Visually Impaired primary caseloads and Deaf/Hearing Impaired primary caseloads were reported by 18 respondents (11.7%).  Twenty-eight respondents (22.7%) indicated a primary caseload of “Other” or “None.” These were generally managers with a specialty caseload, but also included some Rehabilitation Services Associates (RSAs) and Employment Specialists who indicated that they did not have a caseload. The total number of respondents equals more than 100% because several counselors have multiple caseload types.
Office Location
The total number of respondents by district and office location are as follows:
District 1 (33 Respondents)— Charleston-12, Point Pleasant-6, Ripley-5, Teays Valley-10.  
District 2 (26)— Clarksburg-6, Elkins-4, Fairmont-5, Morgantown-7, Weston-4.
District 3 (28)— New Martinsville-2, Parkersburg-6, Weirton-8, Wheeling-12.
District 4 (46)— Beckley-17, Lewisburg-10, Princeton-9, Summersville-10.
District 5 (39)— Huntington-22, Logan-8, Mullens-4, Welch-5.
District 6 (21)— Keyser-6, Martinsburg-7 Moorefield-8, Romney-0.
The numbers for each office are sometimes more than the total number of respondents because some staff work out of more than one office.
Years of Experience in WVDRS Field Services
169 respondents reported the number of years worked in WVDRS Field Services. Respondents had varying amounts of experience working in Field Services, from less than one year to 45 years (mean = 10 years). Fifty-eight respondents (33%) reported four or fewer years of Field Services experience.
Titles Held
176 of respondents reported their titles within Field Services.  Of those, 22 reported their title as Rehabilitation Counselor Trainees, 29 were Rehabilitation Counselors, 30 were Senior Rehabilitation Counselors, and 8 Certified Rehabilitation Counselors.  There were 52 Rehabilitation Services Associates (RSAs), 18 Branch Office Managers/Supervisors, and 3 former District Managers.  There were also 11 Employment Specialists and 3 clerical staff.
Service Need/Use
167 respondents addressed service need/use for each service by indicating which services their consumers need/use most often.  This was done independently of the service gap assessment as some services may be highly needed/used but are readily available and therefore do not require an increase in availability.
The top services are listed for each service category below with the percentage of identified needs in parentheses:
Educational Services  
•	Vocational Education (84.4%)
•	2-year or 4-year College (70.7%)
•	High School (68.3%)
•	Tutoring (62.9%)
•	Special Education (55.7%)
•	Adult Basic Education (50.3%)
Training Services 
•	Career Planning (73.1%)
•	Business Vocational (72.5%)
•	On-the-job Training (65.9%)
•	Job Search Training (64.7%)
•	Work Adjustment Training (64.1%)
•	Independent Living Skills (63.5%)
•	Driver Training (61.1%)
•	Disability Rights Training (52.1%)
Health Services  
•	Psychological/Psychiatric Treatment (73.7%)
•	Eye Care (59.3%)
•	Hearing/Auditory Services (55.7%)
•	Dental Care (51.5%)
Employment and CRP Services  
•	Vocational Counseling & Guidance (76%)
•	Job Placement (68.9%)
•	Psychological Evaluation (68.3%)
•	Community Based Assessment (67.1%)
•	Direct Placement by CRPs (66.5%)
•	Vocational Evaluation (64.7%)
•	Work Skills Assessment (63.5%)
•	Job Coaching other than SE (62.3%)
•	Work Adjustment Training (61.7%)
•	Job Development (59.3%)
•	Work-related tools/equipment (58.7%)
Support Services  
•	Transportation (62.3%)
•	Financial Assistance (52.7%)
•	Assistive Technology Services (49.7%)
•	Vehicle Maintenance/Repair (48.5%)
•	Assistive Devices (44.9%)
•	Childcare (40.1%)
Pre-ETS Services  
•	Job Exploration Counseling (73.1%)
•	Counseling on Postsecondary Opportunities (71.9%)
•	Workplace Readiness Training (70.7%)
•	Work-based Learning Experiences (69.5%)
•	Self-Advocacy Training (67.1%)
Service Gaps
Respondents that indicated a perceived service gap were totaled for each service.  The top five service gaps are listed for each service category below with percentage of respondents in parentheses:
Educational Services 
•	Tutoring (19.2%)
•	Adult Basic Education (18.6%)
•	Literacy Instruction (15%)
•	Vocational Education (13.2%)
•	Graduate Degree Education (6%)
Training Services 
•	Driver Training (33.5%)
•	Sign Language (23.4%)
•	Disability Rights Training (20.4%)
•	Independent Living Skills (20.4%)
•	Reading in Braille (20.4%)
Health Services 
•	Dental Care (29.9%)
•	Psychological/Psychiatric (25.1%)
•	Substance Abuse Treatment (22.2%)
•	Speech/Communication Therapy (17.4%)
•	Occupational Therapy (13.2%)
Employment/CRP Services 
•	Small Business Development (21.6%)
•	Direct Placement by CRPs (18.6%)
•	Job Development (17.4%)
•	Supported Employment (17.4%)
•	Trial Work Experience (17.4%)
Support Services 
•	Transportation (53.3%)
•	Childcare (32.3%)
•	Housing Assistance (30.5%)
•	Financial Assistance (24.6%)
•	Vehicle Modification and Repair (21.6%)
Pre-ETS Services 
•	Work-based Learning Experience (10.8%)
•	Workplace Readiness Training (10.2%)
•	Self-Advocacy Training (7.8%)
•	Counseling on Postsecondary Opportunities (6%)
•	Job Exploration Counseling (6%)
Overall Service Needs for West Virginians with Disabilities
Respondents were asked to identify the top five overall service needs for different consumer groups with which they have experience with providing VR services.  Respondents were asked to indicate if they did not have experience working with the consumer group.  The number and percentage of respondents who indicated a gap for the service are in parentheses followed by the number of responses by WVDRS office location. Some respondents identified more than one office.
Note:  New categories were created to incorporate answers that were not specific to a pre-existing service category from the survey.  For example, the “Overall Training” category was created to include a number of open-ended responses where the respondent indicated a need for training, but not a specific type, such as, “Training options” and “Training services.”  The Miscellaneous category contains individual responses that were not clear in meaning or otherwise could not be grouped into a particular theme.
General Territories
The survey asked participants to “Select the five most needed services by your consumers with significant disabilities in WVDRS general territories that you work with.”  There were 113 respondents to this question.  The most reported service needs were:
•	Transportation (44.3%)
•	Mental Health Counseling (42.5%)
•	2-year to 4-year college (35.4%)
•	CRP Services (35.4%)
•	Vocational Counseling and Guidance (25.7%)
Transitioning Youth
The survey asked, “Select the top five most needed services by your consumers with significant disabilities in transition/school territories that you work with.”  There were 115 respondents to this question. The most reported service needs were:
•	Driver Education, Tutoring and Licensing (42.6%)
•	Transportation (36.5%)
•	2-year to 4-year college (36.7%
•	CRP Services (35.7%)
•	Vocational Counseling and Guidance (32.2%)
Deaf/Hard of Hearing
Respondents were asked, “Select the top five most needed services by your consumers with significant disabilities in deaf/hearing impaired territories that you work with.” There were 48 respondents to this question.  The most reported service needs were:
•	Hearing/Auditory Services (54.2%)
•	Assistive Technology Services (37.5%)
•	Interpreter Services (31.3%)
•	Sign Language (27%)
•	Assistive Devices (cane, wheelchair, etc.) (25%)
Blind/Visually Impaired
Respondents were asked, “Select the top five most needed services by your consumers with significant disabilities in blind/visually impaired territories that you work with.”  There were 25 respondents to this question.  The most reported service needs were:
•	Assistive Technology (64%)
•	Orientation and Mobility Training (56%)
•	Assistive Devices (cane, wheelchair, etc.) (44%)
•	Reading in Braille (40%)
•	Transportation (36%)
Minority Individuals
The survey asked, “Select the top five most needed services by your minority consumers with significant disabilities that you work with.”  There were 144 respondents to this question.  The most reported service needs were:
•	Transportation (43%)
•	2-year to 4-year college (34%)
•	Job Placement (29.9%)
•	CRP Services (26.4%)
•	Overall Training (26.4%)
Barriers to Employment
The survey asked respondents to indicate substantial barriers that are preventing the consumers they serve from gaining and/or maintaining employment.  There were 154 responses to this question.  The top five most frequently indicated barriers to employment were:
•	Transportation (70.4%)
•	Low Income (35.5%)
•	Family Support (34.9%)
•	Childcare (32.3%)
•	Ex-offender (28%)
Integration with Core Partners
WVDRS Field Staff members were asked three open-ended response questions regarding their familiarity, experience, and recommendations on integrating services with Workforce Development System Core Partners of WorkForce WV and WV Adult Education.
Please describe your familiarity with the services that WorkForce WV and WV Adult Education provide.
There were 135 responses to this prompt. Responses were judged to express either high familiarity, some familiarity, limited familiarity, or no familiarity. Sixty-three responses (46.7%) expressed high familiarity. Forty-seven responses (34.8%) indicated some familiarity, 13 (9.6%) expressed limited familiarity, and 12 (8.9%) responses suggested no familiarity.
Please describe the level of need that our consumers with significant disabilities have for the services that WorkForce WV and WV Adult Education provide.
There were 130 responses to this statement. Responses were judged to express either high need, some need, or no indication of need. Sixty-three responses (48.5%) expressed high need. Forty-one responses (31.5%) indicated some need. Eight (6.2%) responses provided no indication of need. In addition, 18 responses (13.8%) provided responses that clearly did not relate to the question.
Please comment on your experiences with integrating service (not including referral) with WorkForce WV and WV Adult Education (e.g., using Labor Market Information, referrals to and from WorkForce WV, co-serving a client with Adult Education). In addition to your experiences, please discuss other activities that WVDRS could conduct with our core partners to further help our consumers with significant disabilities.
There were 130 responses to this statement. Responses were thus categorized: 1) whether the field staff had experience with integrating services with WorkForce WV and WV Adult Education and 2) whether the respondent had sent or received referrals from core partners and 3) whether other activities that WVDRS could conduct with core partners were discussed.
A plurality of respondents (33.1%) indicated experience with integrating services with core partners, 8.5% mentioned that they had referred consumers to partners or had received referrals from partners, and 31.5% of WVDRS Staff explicitly stated that they had limited or no experience with integrating services.
The responses of 21.5% of staff discussed activities that WVDRS could conduct with core partners and others (5.4%) discussed activities that core partners could conduct (e.g., forward labor market research information with a client’s referral) to make things easier. Several others gave no recommendations.
Please provide recommendations on how to better facilitate our partnerships with WorkForce WV and WV Adult Education (e.g., specific cross-trainings, co-location, etc.).
There were 115 staff who responded to this prompt. Suggestions with similar themes were grouped and some respondents provided comments that spanned multiple themes.  The most common recommendation theme involved training or cross-training (generally focusing on learning what other partners provide), with 40% of responses. Having meetings between the partners was the next most common theme (20%), followed by improved communication (18.3%), greater accessibility (12.2%), and better coordination of services (6.1%). Additional responses (21.7%) indicated no recommendation (e.g., “N/A” or “No comment”). 
The numbers add up to more than 100% because some staff provided more than one suggestion.
Comments and Suggestions
What can WVDRS provide to better serve our consumers with significant disabilities and help you perform your job more effectively and efficiently?
There were 125 respondents to this prompt. Suggestions with similar themes were grouped and some respondents provided comments that spanned several themes. The most common response themes were Budget/Staffing (29.6%), Service Provision (18.4%), Training (15.2%), Communication (14.4%), and Technology/Innovation (13.6%).  16.8% had no recommendations. The numbers add up to more than 100% because some staff provided more than one suggestion.
Based on your experience, what services can WVDRS provide to employers to increase the employment of individuals with significant disabilities?
There were 123 respondents to this prompt. Suggestions with similar themes were grouped and some respondents provided comments that spanned several themes. The most common response themes were Employer Education (35.8%), Better Communication and Support (27.6%), On-the-job Training (14.6%), Increasing Rapport (9.8%), and Providing Incentives (8.9%).  19.5% provided no recommendations.
The numbers add up to more than 100% because some staff provided more than one suggestion.
Please provide any additional comments regarding unmet service needs of individuals with significant or most significant disabilities with whom you work.
There were 79 respondents that provided additional comments which were grouped into major themes. Some respondents provided comments that spanned multiple themes.  For instance, 27.8% of responses were related to Service Provision and the next most common responses were for Transportation (21.5%), Budget/Staffing Issues (15.2%), and Policy Changes (6.3%). An additional 31.6% of responses indicated no comment (e.g., “N/A” or “None”).
Discussion
As part of the FY 2024 CSNA, WVDRS field staff members were surveyed on the service needs and gaps within VR for West Virginians with significant disabilities.  The responses will be used in conjunction with other CSNA activities to develop future Combined State Plans, including agency goals and priorities, and related strategies.  A total of 186 WVDRS field staff members provided detailed insight into the perceived service needs and gaps throughout the state.  The current survey responses echo previous CSNA results, with many of the same service needs and gaps being reported.  Overall, the most commonly reported service needs for the FY 2024 CSNA were for Transportation, Overall Training, Job Coaching/Supported Employment Services, Job Placement, and Vocational Counseling and Guidance.  Transportation has consistently been the most often reported barrier for West Virginians with significant disabilities.  WVDRS continues to implement and monitor various strategies to improve transportation availability.
CRP Services
As required by the WIOA, the survey asked respondents to identify any need for CRP services, including Supported Employment (SE).  The top reported CRP service needs were Community-Based Assessment, Work Skills Assessment, Direct Placement, Work Adjustment Training, and Life Skills Training.  In recent years, WVDRS has adopted goals and priorities to improve access to CRP services.  As of November 2023, there are 82 WVDRS-acknowledged parent company CRPs in West Virginia located at 85 service sites. These CRPs provide valuable services throughout the state, benefiting West Virginians with significant disabilities.  Transitioning youth also benefit from CRP services through the provision of pre-employment transition services, including career exploration and work-based learning experiences.
Transitioning Youth
Respondents were asked to provide the top service needs for Transitioning Youth (TY) with significant disabilities.  The top five reported service needs for TY were Transportation, Life Skills Training, Work-Based Learning Experiences, Job Exploration Counseling, and Vocational Counseling and Guidance.  WVDRS will continue to partner with state and local school systems to ensure access to VR and other pre-employment transition services for students with disabilities.  Through these partnerships and shared resources, TY will have increased opportunities to achieve competitive, integrated employment. 
B. Individuals with disabilities who are minorities and individuals with disabilities who have been unserved or underserved by the VR program;
Findings – Consumers with Significant Disabilities from Minority Backgrounds
In 2023, SPPE staff members conducted a qualitative analysis of the reported service needs of 1,209 persons with significant disabilities of various age and disability groups statewide.
Of the statewide total of 1,209 persons with significant disabilities at the time of their WVDRS application, 119 persons (9.8%) were determined to be of minority status. The demographic profile of this subset of minority status individuals with significant disabilities consists of the following characteristics:
- Gender:  56.3% male, 43.7% female;
- Race: 3.4% American Indian or Alaska Native, 3.4% Asian, 73.9% African American, 17.6% Hispanic Latino, 1.7% Pacific Islander;
- Age: 52.9% under 20 years old, 27.7% 20-34 years, 5.0% 35-44 years, 10.9% 45-64 years, 3.4% 65 years or older;
- Primary Impairment: 8.0% Sensory/Communicative Impairments (including blindness, other visual impairments, deafness – primary communication visual, deafness – primary communication auditory, hearing loss – primary communication visual, hearing loss – primary communication auditory, other hearing impairments, deaf-blindness, and communicative impairments), 13.8% Physical Impairments (including mobility orthopedic/neurological impairments, manipulation/dexterity orthopedic/neurological impairments, both mobility and manipulation/dexterity orthopedic/neurological impairments, other orthopedic impairments, respiratory impairments, general physical debilitation, and other physical impairments), 78.2% Mental Impairments (including cognitive impairments, psychosocial impairments, and other mental impairments);
- Referral Source: 2.5% Adult Education and Literacy Programs, 0.8% Community Rehabilitation Programs, 0.8% Consumer Organizations or Advocacy Groups, 1.7% DOL Employment and Training Service Programs, 35.3% Educational Institutions (elementary/secondary), 5.9% Educational Institutions (postsecondary), 0.8% Faith-Based Organizations, 12.6% Family/Friends, 2.5% Medical Health Provider (Public or Private), 3.4% Mental Health Provider (Public or Private), 0.8% Other One-stop Partner, 0.8% Other Sources, 0.8% Other State Agencies, 0.8% Other VR State Agencies, 0.8% Other WIOA-funded Programs, 0.8% Public Housing Authority, 27.7% Self-referral, 0.8% Veteran’s Administration;
- Employment Status at Application: 5.0% Employed, 95.0% Employment not reported;
- Primary Source of Support: 6.7% Personal Income, 73.1% Family and Friends, 17.6% Public Support (SSI, SSDI, TANF, etc.), 2.5% Other (Private disability insurance, Private charities).
Service Needs Reported by Consumers with Significant Disabilities from Minority Backgrounds
Education
Among consumers with significant disabilities from minority backgrounds, 32 of 119 (26.9%) needs comments involved education. Of these 32, education needs identified were categorized as transition (65.6%), 2-year or 4-year college (18.8%), other (9.4%), high school education (3.1%), tutoring (3.1%), assessments (3.1%), accommodations (3.1%), and graduate degree education (3.1%).
The numbers add up to more than 100% because some staff provided more than one suggestion.
Most Frequently Reported Education Needs
Transition (65.6%)
Many responses by consumers with significant disabilities from minority backgrounds indicated a need for transition from school to work. These comments included phrases such as “transition from school to work” or “assistance with transition services.”
2-year or 4-year College (18.8%)
A few of the consumers with significant disabilities from minority backgrounds who expressed needs regarding education were particularly interested in attending and completing college.
This was expressed in a number of ways, such as “assistance with college” or “higher education.”
Training
Among consumers with significant disabilities from minority backgrounds, 35.3%n of needs comments involved training. Of these, training needs identified were categorized as business/vocational training (83.3%), drive training/licensing (14.3%), job search training/assistance (2.4%), and other (2.4%).
Most Frequently Reported Training Needs
Business/Vocational Training (83.3%)
The most identified training need by consumers with significant disabilities from minority backgrounds was training for employment. Within this category, responses were typically of the general sort (e.g., “training and employment”), although a few responses targeted training for specific jobs.
Drive Training/Licensing (14.3%)
Some consumers with significant disabilities from minority backgrounds identified the need for driving skills or legal driving capability. This was generally referred to by phrases such as “driver’s license” or “learn to drive.”
Health
Among consumers with significant disabilities from minority backgrounds, 16% of needs comments involved health. Of these, health needs identified were categorized as psychological/psychiatric (42.1%), hearing/audiological services (31.6%), eye care (10.5%), other (10.5%), physician’s services (2.2%), and hospital services (5.3%).
Most Frequently Reported Health Needs
Psychological/Psychiatric (42.1%)
Needs comments in this category indicated the need for mental health services of some type. However, the specific need varied. Some consumers with significant disabilities from minority backgrounds expressed the need for “counseling” or “mental restoration,” while others were interested in psychological evaluations.
Hearing/Audiological Services (31.6%)
Some consumers with significant disabilities from minority backgrounds identified needs related to hearing. Most of these needs comments specifically stated the need for hearing aids.
Employment/CRP 
Among consumers with significant disabilities from minority backgrounds, 59.7% needs comments involved employment/CRP services. Of these, employment/CRP service needs identified were categorized as job placement (76.1%), vocational counseling and guidance (21.1%), life skills training (5.6), other (5.6%), work-related tools or equipment (2.8), job retention (1.4%), work adjustment training (1.4), and supported employment (SE) (1.4).
Most Frequently Reported Employment/CRP Needs
Job Placement (76.1%)
Nearly half of consumers with significant disabilities from minority backgrounds were primarily interested in placement in a job. Needs comments that specifically included the word “placement” fit into this category. However, some simply stated the need for “employment” or a “job.”
Vocational Counseling and Guidance (21.1%)
Some consumers with significant disabilities indicated a need for vocational counseling and guidance. Key phrases in this category include “vocational planning” and “job exploration.”
Support
Among consumers with significant disabilities from minority backgrounds, 20.2% of needs comments involved support. Of these, support needs identified were categorized as financial assistance (75.0%), assistive technology services (12.5%), other (8.3%), orientation/mobility services (4.2%), and transportation (4.2%).
Most Frequently Reported Support Needs
Financial Assistance (75.0%)
Some consumers with significant disabilities from minority backgrounds identified the need for financial assistance, typically for hearing aids, education, or other training. Key words and phrases for this category include “sponsorship” and “financial assistance.”
Service Needs of Consumers with Significant Disabilities from Minority Backgrounds as Reported by WVDRS Field Staff
In compliance with the Rehabilitation Act, the survey asked respondents to identify the top five service needs of individuals from minority backgrounds.  The most commonly reported service needs were Transportation, 2-year to 4-year College, Job Opportunities, Search and Placement, CRP Services, and Training. 
Service Gaps for Consumers with Significant Disabilities from Minority Backgrounds as Reported by WVDRS Field Staff
The percentage of respondents who indicated a gap for the service are in parentheses.
Note: New categories were created to incorporate answers that were not specific to a pre- existing service category from the survey.  For example, the “Overall Training” category was created to include a number of open-ended responses where the respondent indicated a need for training, but not a specific type; for example, “Training options” and “Training services.”
The survey asked, “Select the top five most needed services by your minority consumers with significant disabilities that you work with.”  There were 144 respondents to this question.  The most reported service needs were:
•	Transportation (43%)
•	2-year to 4-year college (34%)
•	Job Placement (29.9%)
•	CRP Services (26.4%)
•	Overall Training (26.4%)
Minority Populations
In compliance with the Rehabilitation Act, the survey asked respondents to identify the top five service needs of individuals from minority backgrounds.  The most commonly reported service needs were Transportation (43.1%), 2-year to 4-year College (34%), Job Opportunities, Search and Placement (29.9%), CRP Services (26.4%), and Training (26.4%). 
According to data from the U.S. Census Bureau’s 2020 Decennial Census, there are approximately 182,967 racial minorities (including multi-racial) in West Virginia, making up 10.2% of the state’s total population. This is a 3.5 percentage point increase from the 2017 American Community Survey (ACS) 5-Year Estimates, which were used in the PY 2020 WV Unified State Plan. Based on the 2020 Census data, WVDRS exceeded the minority percentage in terms of minority consumers served for PY 2021 (10.7%), PY 2022 (11.3%), and PY 2023 (12.0%).
The 2020 Census Bureau data reveal a total of 14 counties in West Virginia that have minority populations that exceed 3,000: Berkeley (23,795, 19.5% of total county population); Cabell (11,685, 12.4%); Fayette (4,005, 9.9%); Harrison (5,587, 8.5%); Jefferson (10,876, 18.8%); Kanawha (27,108, 15.0%); Marion (5,627, 10.0%); Mercer (7,110, 11.9%); Monongalia (15,810, 14.9%); Ohio (4,656, 11.0%); Preston (3,384, 9.9%); Putnam (4,076, 7.1%); Raleigh (10,566, 14.2%); and Wood (6,126, 7.3%).
In each year since PY 2021, the WVDRS minority service percentage has exceeded the county minority population percentage in only five of the 14 aforementioned counties: Fayette, Kanawha, Mercer, Ohio, and Raleigh. The counties of Berkeley, Cabell, Harrison, Jefferson, Marion, Putnam, and Wood had a WVDRS minority service percentage that met or exceeded the county minority population percentage in at least one PY since 2021. The WVDRS minority service percentage was below the county minority population percentage in each year since PY 2021 for the counties of Monongalia and Preston.
Below is a list of each of these 14 counties (with its respective minority population and percentage in parentheses), followed by the WVDRS minority service percentage for each county in PY 2021, PY 2022, and PY 2023.
Berkeley (23,795, 19.5%): PY 2021 – 15.7%; PY 2022 – 21.6%; PY 2023 – 25.3%
Cabell (11,685, 12.4%): PY 2021 – 10.9%; PY 2022 – 12.4%; PY 2023 13.2%
Fayette (4,005, 9.9%): PY 2021 – 17.0%; PY 2022 – 13.5%; PY 2023 – 14.5%
Harrison (5,587, 8.5%): PY 2021 – 5.6%; PY 2022 – 9.0%; PY 2023 – 10.5%
Jefferson (10,876, 18.8%): PY 2021 – 18.4%; PY 2022 – 20.3%; PY 2023 – 24.5%
Kanawha (27,108, 15.0%): PY 2021 – 18.6%; PY 2022 – 18.3%; PY 2023 – 17.7%
Marion (5,627, 10.0%): PY 2021 – 8.3%; PY 2022 – 12.8%; PY 2023 – 11.3%
Mercer (7,110, 11.9%): PY 2021 – 14.6%; PY 2022 – 16.0%; PY 2023 – 14.6%
Monongalia (15,810, 14.9%): PY 2021 – 10.6%; PY 2022 – 13.1%; PY 2023 – 14.4%
Ohio (4,656, 11.0%): PY 2021 – 12.2%; PY 2022 – 15.6%; PY 2023 – 20.8%
Preston (3,384, 9.9%): PY 2021 – 5.5%; PY 2022 – 3.7%; PY 2023 – 2.7%
Putnam (4,076, 7.1%): PY 2021 – 5.7%; PY 2022 – 7.3%; PY 2023 – 5.2%
Raleigh (10,566, 14.2%): PY 2021 – 15.8%; PY 2022 – 16.0%; PY 2023– 21.1%
Wood (6,126, 7.3%): PY 2021 – 8.5%; PY 2022 – 6.6%; PY 2023 – 6.4%
The 2020 Decennial Census data indicated two counties in West Virginia with a minority population under 3,000 and a county minority population percentage equal to or greater than the State’s minority population percentage of 10.2%: Gilmer (1,382; 18.7%) and Hardy (1,614, 11.3%). Neither of these two counties had a WVDRS minority service percentage higher than its respective county minority population percentage since PY 2021. Below is a list of each of these counties (with its respective minority population and percentage in parentheses), followed by the WVDRS minority service percentage for each county in PY 2021, PY 2022, and PY 2023.
Gilmer (1,382; 18.7%): PY 2021 – 11.1%; PY 2022 – 10.0%; PY 2023 – 11.4%
Hardy (1,614, 11.3%): PY 2021 – 6.2%; PY 2022 – 7.7%; PY 2023 – 6.8%
To determine potentially underserved areas, the average WVDRS minority service percentage for the three-year period (PY 2021– PY 2023) for each county was compared to that county’s total minority population percentage. Counties with mean WVDRS minority service percentages that are lower than their minority population percentage are considered to be potentially underserved. Of the 16 aforementioned counties, eight counties met this criterion: Cabell, Gilmer, Hardy, Harrison, Monongalia, Preston, Putnam, and Wood. It is important to note that as previously described, some of these counties had a minority service percentage that exceeded the county’s minority population percentage in select fiscal years.
WVDRS will expand and enhance its outreach activities, particularly in the counties identified through this process, to ensure awareness of and access to its services in potentially underserved areas and among potentially underserved populations.  WVDRS will continue to work with community partners and stakeholders to maximize the impact of outreach activities and increase referrals.
As has been the case for many years, WVDRS’ direct client services units located at WVDRS’ Nitro location will continue to be critical for WVDRS to meet the needs of individuals with disabilities who would otherwise be unserved and/or underserved, including individuals with disabilities who live in the rural parts of the State, blind and visually impaired individuals, and the deaf and hard of hearing. The WVDRS Environmental Modifications Unit provides consumer services to assure they have the highest level of independence in and around their home and work by providing evaluations, technical assistance, and modifications.
C. Individuals with disabilities served through other components of the workforce development system; and
Introduction
One requirement of the CSNA is an assessment of the rehabilitation needs of individuals with disabilities served through other components of the statewide workforce development system. In West Virginia, this system is overseen at the state level by the State Workforce Development Board (WDB) and the Interagency Collaborative Team (ICT) and locally by seven Local Workforce Development Boards (LWDBs) that preside over localized workforce development system activities. The State and Local WDBs are comprised of representatives from business, labor, and public agencies.
As part of the FY 2024 Comprehensive Statewide Needs Assessment, the West Virginia Division of Rehabilitation Services (WVDRS) emailed a survey to all members of the ICT in June of 2023. In addition to the seven regional Workforce Development Board (WDB) directors, ICT membership includes the following WV state agencies:
•	Bureau of Senior Services	
o	State Unit on Aging
•	Council for Community and Technical College
•	Department of Education	
o	Office of Adult Education and Workforce Development
o	Office of Diversion and Transition Programs
•	Department of Commerce	
o	WVDRS
o	WorkForce WV		
•	WV Employment Service
o	Development Office		
•	Community Development Division
•	Business Industry Development Representatives
•	Department of Veterans Assistance
•	Department of Health and Human Resources	
o	Bureau of Children and Families
o	Temporary Assistance for Needy Families
o	Food Stamp Employment and Training
Workforce Development Board Regions
American Job Centers are physical locations where consumers, including those with disabilities, can utilize services provided by partner agencies operating under the Workforce Innovation and Opportunity Act. WorkForce WV is the agency, within the WV Department of Commerce, that operates American Job Centers across the seven workforce development regions across the state. WVDRS’ involvement in the State WDB, ICT, and LWDBs in addition to its presence at American Job Centers ensures that people with disabilities are considered for employment training needs and services are identified.
Please note that there are seven workforce development regions in West Virginia, whereas WVDRS has six regions. The following provides the breakdown of American Job Centers by type and workforce development region:
•	Region One consists of two comprehensive centers and four affiliate centers. The Local Workforce Development Board (LWDB) oversees service delivery in 11 counties of southeastern WV: Fayette, Greenbrier, McDowell, Mercer, Monroe, Nicholas, Pocahontas, Raleigh, Summers, Webster, and Wyoming. The region is mountainous and rural in nature. The coal industry continues to fluctuate throughout the region with extensive layoffs and hiring taking place on a frequent basis. The dynamics of the workforce have drastically changed because of the COVID-19 pandemic. Employers are now hiring, but job seekers are not applying for jobs and re-entering the workforce as rapidly as employers need. Virtual job fairs, promotion of positions available, and partner services are being offered to aid employers with hiring needs. On a positive note, program participation increased during the pandemic. Career and employability services are offered to assist job seekers who seek aid with resumes, job search, and other employment activities. Industry expected growth in the area includes but is not limited to: Ambulatory Health Care Services, Social Assistance, Waste Management and Remediation Service, Heavy and Civil Engineering Construction, and Construction of Buildings.
•	Region Two consists of one comprehensive center, two satellite sites, and six affiliate sites-including four Community and Technical College (CTC) sites throughout the counties of Boone, Cabell, Logan, Mingo, Putnam, and Wayne. The affiliate sites provide Workforce Innovation and Opportunity Act (WIOA) and Temporary Assistance for Needy Families (TANF) services in all locations. Medical-related occupations make up 16 of the top 25 occupations in the region. Non-Medical occupations are led by: Market Research Analysts, Photographers, Personal Financial Advisors, Nonfarm Animal Caretakers, Hair Stylists, Plumbers, CDL Truck Drivers, and Computer and Information.
•	Region Three consists of Kanawha County with a population of approximately 180,745 people, making it West Virginia’s most populous county. Its county seat is Charleston, the state capital. Kanawha County is part of the Charleston, West Virginia, Metropolitan Statistical Area, the state's business, financial, medical, and governmental center. Kanawha County encompasses 902 square miles. Within Kanawha County there are eight cities, eight towns and 12 unincorporated communities. 75% of the county is urban; 25% is rural. Kanawha County serves as the central employment location for a nine-county area. More than 11,000 people commute from neighboring Putnam County, while more than 2,000 people commute from Boone and Lincoln counties combined. Adjustments were made to how Region III provides services to employers and participants during the Covid-19 pandemic, including the use of a virtual platform that allowed staff to provide services, connect participants with our partner agencies, and host job fairs.
•	Region Four consists of nine counties that comprises a region of rural and urban populations. It is served by one comprehensive center and six affiliate centers. Those counties are Calhoun, Clay, Jackson, Mason, Pleasants, Ritchie, Roane, Wirt, and Wood. The population of the combined nine counties is just under 200,000 individuals.
•	Region Five has two comprehensive AJCs in the cities of Weirton and Wheeling and one satellite AJC in the city of New Martinsville. The LWDB’s region of services includes Hancock, Brooke, Ohio, Marshall, Wetzel, and Tyler Counties. WIOA, Supplemental Nutrition Assistance Program (SNAP), and National Health Emergency Grant (NHEG) funds are used to assist eligible individuals and area employers with their training, support, and hiring needs. Long-term occupations by industry in the region include Health Care & Social Assistance, Ambulatory Health Care Services, Nursing and Residential Care Facilities, Construction, Hospitals, and Educational Services. High-demand occupations for a ten-year period in the region include Registered Nurses, Home Health Aides, Nursing Assistants, Clergy, Construction Laborers, Light Truck and Tractor Trailer Operators, and Secondary School teachers.
•	Region Six consists of one comprehensive center and three affiliate centers that serve the following 13 counties in North Central West Virginia: Barbour, Braxton, Doddridge, Gilmer, Harrison, Lewis, Marion, Monongalia, Preston, Randolph, Taylor, Tucker, and Upshur. The public sector is still the main feature of North Central WV’s economic development with the presence of many higher education institutions, correctional facilities, and the U.S. Federal Bureau of Investigation (FBI) in Harrison County. Healthcare services represent another cornerstone to the North Central Region 6 economy with the presence of several hospitals and various other healthcare facilities, most namely WVU Medicine which is supposed to increase its footprint in the area with the forthcoming opening of WVU Children’s Hospital in Monongalia County. Region 6 will share the spotlight, along with Region 7, with the $500 million development project centered around the construction of the Virgin Hyperloop located on an 800-acre tract that encompasses both Grant and Tucker counties. The construction of the high-speed pod-and-tub transportation loop is projected to bring thousands of construction jobs and millions of dollars in economic impact to the State.
•	Region Seven consists of two comprehensive centers. Eight counties are served by the LWDB including Berkeley, Grant, Hampshire, Hardy, Jefferson, Mineral, Morgan, and Pendleton. The region offers a contrast of the rural in western counties and fast-paced suburban sprawl of the eastern counties, part of the Washington D.C. Metropolitan Statistical Area. The region expects the population in the easternmost counties to continue to show rapid growth. The western counties are also anticipated to show growth, albeit at a slower pace. Healthcare, Transportation, Agriculture, Cyber Security, Computer Science, Warehousing, Advanced Manufacturing, Professional Services, as well as Leisure and Hospitality are all primary contributors to the expanding regional economy.
Survey
The survey consisted of eight questions to collect information about the respondent, the agency they represent, and their perception of the rehabilitation service needs and gaps of the individuals with significant disabilities that they serve, as well as employers. The questions were as follows:
1.	Name
2.	Title
3.	Agency
4.	Approximately how many consumers with significant disabilities are served by your agency per year?
5.	Please identify up to five vocational rehabilitation and support services most needed by consumers with significant disabilities served by your agency (e.g., transportation, career exploration, education/training, soft skills training, assessment for accommodations, financial assistance, job search/placement, etc.).
6.	Please identify up to five vocational rehabilitation and support services gaps - those that are needed but not available in sufficient quantities for consumers with significant disabilities served by your agency.
7.	Please identify up to five disability-related services employers need (e.g., workplace accommodations, assistive technology, staffing assistance, tax credit information, disability etiquette training, etc.).
8.	How can WVDRS assist your agency to better serve your customers with significant disabilities?  Please add any additional comments here.
Results
A total of nine surveys were completed online. Respondents represented Workforce WV, WV Adult Education, WV Office of Economic Development, Department of Health and Human Resources (DHHR) Office of Family Assistance, WV Department of Veterans Assistance and WDB Regions 2 and 6.
Number of Individuals with Disabilities Served
The approximate number of consumers with disabilities served by each agency varied from 0 to 3000. Four respondents were unable to provide a response for this question.
Services Most Often Needed
All respondents replied to this prompt, although one of them indicated that the question could not be answered due to a lack of clients.  The most reported service needs were education assistance, job search/placement, transportation, financial assistance, and soft skills/employability skills training.
Service Gaps
Six respondents provided service gap information.  The responses included assessments, transportation, financial assistance, assistive technology, education/training, mental health practitioners, childcare, and case management.
Services to Employers
All five respondents provided services to employer information. The most reported service needs were disability etiquette training, information regarding accommodations, staffing assistance, and equipment/assistive technology.
WVDRS Assistance and Additional Comments
Six respondents provided comments in response to this prompt. Respondents encouraged a continuation of the services and partnership that WVDRS provides, suggestions for better communication to streamline services and referrals, recommendations for improved database interface between involved agencies, and a more active role in marketing services to veterans.
Discussion
The West Virginia Division of Rehabilitation Services takes the input of its partners seriously and plans to use the information provided to make well-informed decisions regarding policy and service provision moving forward. As WVDRS continues to provide vocational rehabilitation services to individuals with the most significant disabilities, the agency will continue to collaborate, as needed, with its core WIOA partners of WorkForce WV and WV Adult Education, as well as with fellow ICT members. This collaboration will ensure that individuals with the most significant disabilities receive maximized service provision in their mission to obtain competitive, integrated employment.
D. Youth with disabilities, including students with disabilities and their need for pre-employment transition services. Include an assessment of the needs of individuals with disabilities for transition career services and pre-employment transition services, and the extent to which such services are coordinated with transition services provided under IDEA.
SPPE staff members in 2023 conducted a qualitative analysis of the reported service needs of 1,209 persons with significant disabilities of various age and disability groups statewide. These individuals represent a good sample of consumers with significant disabilities that will continue to seek assistance from agencies in coming years, ceteris paribus. All 55 counties in West Virginia were represented in the sample and the sample resembles population proportions by county. SPPE staff members separately analyzed the needs comments of the 757 transitioning youth with disabilities included in the sample.
Of the statewide total of 1,209 persons with significant disabilities at the time of their WVDRS application, 757 persons (62.6%) were determined to be of transition status (age 24 and under). The demographic profile of this subset of transition status individuals with significant disabilities consists of the following characteristics:
- Gender: 50.3% male, 49.3% female, 0.4% did not specify;
- Race: 88.6% White, 11.1% Other (African American/Hispanic Latino/American Indian or Alaska Native/Asian/Pacific Islander), 0.3% Unspecified;
- Age: 79.4% under 20 years old, 20.6% 20-34 years;
- Primary Impairment: 4.1% Sensory/Communicative Impairments (including blindness, other visual impairments, deafness – primary communication visual, deafness – primary communication auditory, hearing loss – primary communication visual, hearing loss – primary communication auditory, other hearing impairments, deaf-blindness, and communicative impairments), 10.2% Physical Impairments (including mobility orthopedic/neurological impairments, manipulation/dexterity orthopedic/neurological impairments, both mobility and manipulation/dexterity orthopedic/neurological impairments, other orthopedic impairments, respiratory impairments, general physical debilitation, and other physical impairments), 85.5% Mental Impairments (including cognitive impairments, psychosocial impairments, and other mental impairments);
- Referral Source: 0.9% Adult Education and Literacy Programs, 0.3% Child Protective Services, 1.2% Community Rehabilitation Programs, 0.8% Consumer Organizations or Advocacy Groups, 48.9% Educational Institutions (elementary/secondary), 7.4% Educational Institutions (postsecondary), 0.1% Faith-Based Organizations, 18.9% Family/Friends, 0.4% Intellectual and Developmental Disabilities Providers, 1.3% Medical Health Provider (Public or Private), 2.0% Mental Health Provider (Public or Private), 0.4% One-stop Employment/Training Centers, 1.8% Other Sources, 0.3% Other State Agencies, 0.1% Other VR State Agencies, 0.1% Other WIOA-funded Programs, 0.1% Public Housing Authority, 14.4% Self-referral, 0.4% Welfare Agency (State or local government);
- Employment Status at Application: 4.7% Employed, 95.3% Employment not reported;
- Primary Source of Support: 5.8% Personal Income, 86.8% Family and Friends, 5.9% Public Support (SSI, SSDI, TANF, etc.), 1.3% Other (Private disability insurance, Private charities).
Service Needs Reported by Transitioning Youth with Significant Disabilities
Education
Education needs were identified in 34.7% of the needs comments of transitioning youth with significant disabilities. Of these, education needs identified were categorized as transition (54.8%), 2-year or 4-year college (37.6%), other (8.0%), accommodations (2.7%), vocational education (2.3%), tutoring (2.3%), high school education (1.5%), assessments (1.1%), graduate education (0.8%), and adult basic education (0.4%).
Most Frequently Reported Education Needs
Transition (54.8%)
Most responses by transitioning youth with significant disabilities indicated a need for transition from school to work. These comments included phrases such as “help with transitioning after high school” or “assistance with transition services.”
2-year or 4-year College (37.6%)
Several of the transitioning youth with significant disabilities who expressed needs regarding education were interested in attending and completing college. Many of these needs comments were general (e.g., “help going to college”), but some others were specific, indicating a particular school of interest or a particular major.
Other (8.0%)
Some responses by transitioning youth with significant disabilities indicated a need for education, or assistance with education, but were not much more specific than that. A typical response in this manner may have included phrases such as “help with school” or “educational services.”
Training
Among transitioning youth with significant disabilities, 42.8% of 757 needs comments involved training. Of these, training needs identified were categorized as business/vocational training (86.7%), drive training/licensing (11.7%), job search training/assistance (4.6%), other (2.1%), and independent living skills (1, 0.3%).
Most Frequently Reported Training Needs
Business/Vocational Training (86.7%)
The most identified training need by transitioning youth with significant disabilities, by a substantial margin, was training for employment. Within this category, responses varied from the general (e.g., “training services”) to the specific (e.g., “phlebotomy program at Med Care”).
Driver Training/Licensing (11.7%)
Some transitioning youth with significant disabilities identified the need for driving skills or legal driving capability. This was referred to in a number of ways, including “driver’s license,” “driver’s training,” or “learner’s permit.” CDL training was also included in this category.
Health
Among transitioning youth with significant disabilities, 5.9% of 757 needs comments involved health. Of these, health needs identified were categorized as psychological/psychiatric (68.9%), hearing/audiological services (20.0%), eye care (4.4%), physician’s services (2.2%), hospital services (2.2%), and other (2.2%).
Most Frequently Reported Health Needs
Psychological/Psychiatric (68.9%)
Needs comments in this category indicated the need for mental health services of some type. However, the specific needs varied. Some transitioning youth with significant disabilities expressed the need for “therapy,” “counseling,” or “mental restoration,” while others were interested in psychological evaluations.
Hearing/Audiological Services (20.0%)
Some of the health needs comments by transitioning youth with significant disabilities were related to hearing. Most of these needs comments specifically stated the need for hearing aids.
Employment/CRP
Among transitioning youth with significant disabilities, 59.2% of 757 needs comments involved employment/CRP services. Of these, employment/CRP service needs identified were categorized as job placement (75.0%), vocational counseling and guidance (27.9%), other (5.1%), life skills training (1.6%), work-related tools or equipment (1.6%), supported employment (SE) (0.7%), job retention (0.4%), vocational evaluation (0.2%), psychological evaluation (0.2%), community-based assessment (0.2%), work skills assessment (0.2%), and job coaching other than SE (0.2%).
Most Frequently Reported Employment/CRP Needs
Job Placement (75.0%)
A large percentage of transitioning youth with significant disabilities were primarily interested in placement in a job. Needs comments that specifically included the word “placement” fit into this category. However, many stated the need for “work” or “employment.”
Vocational Counseling and Guidance (27.9%)
Some transitioning youth with significant disabilities indicated a need for vocational counseling and guidance. Key phrases in this category include “vocational counseling and guidance,” “career exploration,” and “planning a vocational goal.”
Other (5.1%)
Some transitioning youth with significant disabilities indicated a need for services related to employment, but the need indicated was either too general to be classified (e.g., “vocational services”) or otherwise didn’t fit in one of the sub-categories (e.g., “interview skills”).
Support
Among transitioning youth with significant disabilities, 11.4% of 757 needs comments involved support. Of these, support needs identified were categorized as financial assistance (88.4%), assistive technology services (5.8%), other (3.5%), housing assistance (1.2%), and orientation/mobility services (1.2%).
Most Frequently Reported Support Needs
Financial Assistance (88.4%)
Many transitioning youths with significant disabilities identified the need for financial assistance, usually for education or other training. Key words and phrases for this category include “assistance with educational expenses,” “sponsorship,” and “tuition assistance,” among others.
Assistive Technology Services (5.8%)
Some transitioning youth with significant disabilities identified the need for assistive technology. These needs comments specifically indicated “assistive technology” or “AT.”
IDENTIFYING STUDENT NEEDS AS REPORTED BY WVDRS FIELD STAFF
WIOA requires that the comprehensive statewide needs assessment include an assessment of the vocational rehabilitation service needs of “youth with disabilities and students with disabilities, including their need for pre-employment transition services.” WVDRS field staff that serve transitioning youth are one key resource in identifying the service needs of youth with disabilities in West Virginia. Therefore, needs assessment surveys completed by 186 WVDRS field staff were analyzed in order to identify students’ needs for Pre-ETS.
Overall Service Needs for Transitioning Youth (ages 14-24)
The survey asked, “Select the top five most needed services by your consumers with significant disabilities in transition/school territories that you work with.”  There were 115 respondents to this question. The most reported service needs were:
•	Driver Education, Tutoring and Licensing (42.6%)
•	Transportation (36.5%)
•	2-year to 4-year college (36.7%)
•	CRP Services (35.7%)
•	Vocational Counseling and Guidance (32.2%)
Pre-ETS Service Needs for Students with Disabilities (ages 14-21)
Services that were identified as needed by 50% or more of the total respondents are listed for each service category below with the percentage of respondents in parentheses:
•	Job Exploration Counseling (73%)
•	Work-Based Learning Experiences (70%)
•	Self-Advocacy Training (67%)
•	Counseling on Postsecondary Opportunities (72%)
•	Workplace Readiness Training (71%)
Pre-ETS Service Gaps
Respondents that indicated a perceived service gap were totaled for each service.  The top five service gaps are listed for each service category below with percentage of respondents in parentheses:
•	Work-based Learning Experience (10.8%)
•	Workplace Readiness Training (10.2%)
•	Self-Advocacy Training (7.8%)
•	Counseling on Postsecondary Opportunities (6%)
•	Job Exploration Counseling (6%)
RESULTS OF THE ANALYSIS OF THE REPORTED PRE-EMPLOYMENT TRANSITION SERVICES PROVISION BY WEST VIRGINIA HIGH SCHOOLS TO STUDENTS WITH DISABILITIES
In October 2023, as part of the Comprehensive Statewide Needs Assessment, WVDRS conducted an assessment of the need and availability of Pre-ETS for students with disabilities at high schools across the state. The five required Pre-ETS activities (as mandated by WIOA) for students with disabilities are:
1.	Job exploration counseling
2.	Work-based learning experiences
3.	Counseling on opportunities for transitioning from school to work or into postsecondary training or education programs, including college, university (Counseling on Postsecondary Opportunities)
4.	Workplace readiness training to develop social skills and independent living skills
5.	Instruction in self-advocacy
To assess the availability of Pre-ETS for students with disabilities at high schools, WVDRS counselors held formal meetings with school principals, vice principals, counselors, special education teachers, and other related staff. During these meetings, WVDRS counselors asked school staff, for each of the five required Pre-ETS activities, whether the service was currently available to the school’s students with disabilities, and if so, how the service was provided.
The SPPE Unit rated each of the responses to the five Pre-ETS questions using a 1-3 Likert scale.
A rating of 1 indicated that the school does not provide the service (or has a very limited capacity) to its students with disabilities. A rating of 2 indicated that the school was providing services to some students with disabilities but not all, or by providing a minimal level of service to all students with disabilities, suggesting remaining unmet need/demand. Finally, a rating of 3 indicates that the school was sufficiently providing the service to its students with disabilities.
Results
A total of 94 surveys were collected. However, three surveys were eliminated from analysis due to a lack of school identification and meaningful data. The final sample consisted of 91 surveys, collected from 64 high schools from 29 of the state’s 55 counties. All six WVDRS districts were represented.
Total scores for each survey were calculated by adding the scores for each required Pre-ETS activity. A total score of 5 would indicate that none of the services were being provided by the school, while a total score of 15 would indicate that all five required activities of Pre-ETS were provided sufficiently by the school. Schools responding to the survey multiple times had their scores averaged. Twelve schools had a total score of 5 and no school had a total score of 15. Total scores ranged from 5 to 14, with a mean of 7.7 and a mode of 5.
For each service, statewide average scores were calculated, ranging from 1 (indicating no provision of service in high schools across the state) to 3 (indicating sufficient service provision by all high schools in the state). The most sufficiently provided Pre-ETS statewide was Job Exploration Counseling (1.55) and Workplace Readiness Training (1.55), followed by Counseling on Postsecondary Opportunities (1.41), Work-Based Learning Experiences (1.40), and Instruction in Self-Advocacy (1.40). Across all five Pre-ETS categories, the statewide average score was 1.48.
Across all five required Pre-ETS activities statewide, a rating of 1 was scored for a total of 275 responses (Job Exploration Counseling – 51; Work-Based Learning Experiences – 57; Counseling on Postsecondary Opportunities – 61; Workplace Readiness Training – 48; and Instruction in Self-advocacy – 58), a rating of 2 was scored for a total of 141 responses (Job Exploration Counseling – 28; Work-Based Learning Experiences – 30; Counseling on Postsecondary Opportunities – 21; Workplace Readiness Training – 34; and Instruction in Self-advocacy – 28), and a rating of 3 was scored for a total of 39 responses (Job Exploration Counseling – 12; Work-Based Learning Experiences – 4; Counseling on Postsecondary Opportunities – 9; Workplace Readiness Training – 9; and Instruction in Self-advocacy – 5).
Applied thematic analysis was used to determine themes in the recorded service gaps that were identified by respondents. For Job Exploration Counseling, respondents identified gaps related to the accessibility and availability of resources, including transportation, job opportunities, and staffing; information and awareness regarding services and options; and difficulties in working with parents. For Work-Based Learning Experiences, identified gaps were related to transportation and the availability of opportunities for experiences. For Counseling on Postsecondary Opportunities, identified gaps were related to support and involvement from parents, as well as assistance with completing college applications. For Workplace Readiness Training, identified gaps were related to transportation and a lack of training opportunities. For Instruction in Self-advocacy, identified gaps were related to a lack of resources and training opportunities.
The results of the survey indicate that many high schools in West Virginia are providing some level of required Pre-ETS activity. However, there are many locations within the state in which Pre-ETS are not provided or are provided minimally by the school. Several schools indicated that the required Pre-ETS activities are being provided by WVDRS or by a Community Rehabilitation Program. Additionally, respondents identified a number of gaps in service provision. Many of these gaps centered on a need for transportation, training opportunities, and human resources. To ensure that Pre-ETS are available to students with disabilities in high schools statewide, as well as eliminate duplication of services, WVDRS will prioritize and emphasize Pre-ETS provision in categories and high schools which were rated as 1, with secondary priority to those high schools and Pre-ETS categories which were rated as 2. Additionally, WVDRS will continue to explore and expand options for Pre-ETS provision and best practices statewide.
2. Identify the need to establish, develop, or improve community rehabilitation programs within the State.
As described throughout the Comprehensive Statewide Needs Assessment, WVDRS’ direct client services units are crucial for WVDRS to meet the needs of individuals with disabilities identified under the unserved and underserved portion of this assessment, including individuals with disabilities who live in the rural parts of the State, blind and visually impaired individuals, and individuals who are deaf or hard of hearing. WVDRS’ direct client services units focus on providing specialized services for consumers with sensory impairments, which includes those who are blind, visually impaired, deaf or hard of hearing; rehabilitation technology, which includes job accommodations, product fabrication and driver education; assistive technology; and environmental modifications, which ensures consumers have the highest level of independence in and around their home and work by providing evaluations, technical assistance, and modifications. Ongoing development and improvement of direct client services units are necessary to maintain its operation in the most efficient and cost-effective manner possible.
SURVEY OF CRPs/CSPs
As part of the FY 2024 CSNA, WVDRS conducted a survey of CRPs/community service providers (CSPs) with acknowledged vendor status to provide services (including supported employment services) to WVDRS consumers across the state.
A survey for CRPs was developed online, with a request that service providers indicate the types of services provided for WVDRS consumers and the counties in which those services are provided. CRPs were asked to indicate the service types from a list, with an additional option to include an “other” service. CRPs were also asked to indicate which Pre-Employment Transition Services they provided to students with disabilities.
CRPs were also asked to rate their communication with WVDRS personnel using a 5-point Likert scale, ranging from Excellent to Very Poor, and whether the WVDRS liaison counselor was in contact on a regular basis. Finally, CRPs were given the opportunity to provide comments on 1) their communication with WVDRS, 2) specific things WVDRS could do to improve services or service delivery, and 3) what, if anything, the CRP urgently needed to better serve West Virginians with significant disabilities.  The full survey is as follows:
This survey is part of the 2024 West Virginia Division of Rehabilitation Services’ (WVDRS) Comprehensive Statewide Needs Assessment and your responses are critical to ongoing program improvement and expansion to better serve West Virginians with significant disabilities. 
1.	Contact information for the CRP/CSP:
•	Name
•	Company
•	Phone Number
2.	For which counties do you provide services? (Checkbox for each county)
3.	Please indicate the types of services your CRP/CSP provides for WVDRS consumers. (Checkboxes)
•	Community-based assessment
•	Counseling on postsecondary opportunities
•	Direct Placement
•	Extended Assessments
•	Extended Supported Employment (ESES)
•	Job Coaching (Other than SE)
•	Job Exploration Counseling
•	Life Skills
•	Self-Advocacy Training
•	Supported Employment (SE)
•	Work Adjustment Training
•	Work-based Learning Experience
•	Work Skills Assessment
•	Workplace Readiness Training
•	Other
4.	Please indicate which Pre-Employment Transition Services (Pre-ETS) listed below you provide to students with disabilities (i.e., enrolled in school and under the age of 21). (Checkboxes)
•	Counseling on postsecondary enrollment opportunities
•	Job exploration counseling
•	Self-advocacy training
•	Work-based learning experience
•	Workplace readiness training
5.	Please describe your perception of communication between your CRP/CSP and WVDRS personnel today. (Checkboxes)
•	Excellent
•	Very Good
•	Good
•	Poor
•	Very Poor
6.	Does your WVDRS counselor contact you on a regular basis? (Multiple Choice)
•	Yes
•	No
7.	Please provide additional comments regarding your responses on communication with WVDRS personnel. (Comment box)
8.	Please identify specific things that WVDRS can do to improve services or service delivery for West Virginians with significant disabilities. (Comment box)
9.	What else does your CRP/CSP urgently need to better serve West Virginians with significant disabilities? (Comment box)
Results
Service Provision
Sixty-one CRPs responded to the survey.  In each of the six WVDRS districts, all nine categories of services were reported as being provided. Services were also reported as being provided in all 55 counties in West Virginia. All nine services were reported as being provided in 45 out of 55 counties (81.8%). The remaining counties were reported to be provided with between three and eight CRP services. Additionally, in several counties, various services were reported as provided by multiple CRPs. However, based on records in the WVDRS CRP directory, all nine categories of CRP services are provided in all 55 counties. Response counts for provision of each of the service categories are presented in Table 1.
Pre-Employment Transition Services
All five categories of Pre-ETS were reported as being provided by CRPs in all six WVDRS districts. Services were also reported as being provided by CRPs in all 55 counties in West Virginia, with all five categories of Pre-ETS being reported as provided in 46 of 55 counties (83.6%). The remaining counties were provided with between one and four categories of Pre-ETS. Additionally, in some counties, various Pre-ETS were provided by multiple CRPs. Response counts for provision of each of the Pre-ETS service categories are presented in Table 2.
Table 1. CRP Response Counts for Provision of Service Categories
Service	Number of Respondents Reporting Provision	Percentage of Respondents (N = 61)	
CBA	49	80.3%	
DP	43	70.5%	
EA	20	32.8%	
ESE	31	50.8%	
JCOTHER	40	65.6%	
LS	46	75.4%	
SE	41	67.2%	
WAT	44	72.1%	
WSA	39	63.9%	
OTHER	23	37.7%	
Table 2. CRP Response Counts for Provision of Pre-ETS Service Categories
Pre-ETS Service	Number of Respondents Reporting Provision	Percentage of Respondents (N = 61)	
CPSO	28	45.9%	
JEC	33	54.1%	
SAT	33	54.1%	
WBLE	40	65.6%	
WRT	35	57.4%	
Communication and Liaison Contact
All 61 of the CRP respondents provided a rating of their communication with WVDRS. Options ranged from Excellent to Very Poor. No CRPs gave a rating of Very Poor and 58 of the 61 CRPs (95.1%) gave a response of Good or better. Table 3 shows the breakdown of responses.
Table 3. CRP Responses Regarding Communication with WVDRS
Response Option	Number (percentage)	Cumulative Percentage	
Excellent	16(26.2%)	26.2%	
Very Good	15 (24.6%)	50.8%	
Good	27 (44.3%)	95.1%	
Poor	3 (4.9%)	100.0%	
Very Poor	0 (0.0%)	100.0%	
When asked whether a WVDRS liaison counselor was in contact on a regular basis, 35 of 61 CRPs responded yes, while 26 CRPs responded no (57.4% and 42.6%, respectively). All respondents answered this question.
Comments
Communication
 Forty-three of 61 CRP respondents gave additional comments regarding communication with WVDRS. Most of these comments were positive (e.g., “Communication very fluid, constant, and results oriented!”), but a few negative comments were noted as well that generally focus on a lack of communication or that the CRP must initiate any interaction.
WVDRS Improvement
Thirty-five of 61 CRP respondents gave comments regarding specific things that WVDRS could do to improve services or service delivery. The most common themes found in the comments were in higher fee schedules (e.g., “The fee schedule needs to increase so that providers can pay their staff”) and networking (e.g., “A way for CRPs to network with community businesses to establish relationships for CBA, WAT, and WBLE placements”). Other themes referred to WVDRS staffing (e.g., “More DRS counselors”) and service provision issues (e.g., “…more personalized services…can be difficult to address individual needs in a group setting”).
CRP Needs
Thirty-six of 61 CRP respondents gave comments on what the CRP urgently needed to better serve West Virginians with disabilities. Referrals and authorizations (which generate funding for CRPs) were the most reported needs. These comments ranged from the convenient (e.g., “The only issues I’ve had is for referrals to be sent, it’s not happening right away”) to the necessary (e.g., “Referrals to reach underserved school systems”). Other themes that could be found in the comments included increases/improvements in service provision, transportation, and improved willingness of employers to facilitate placement. Other topics were mentioned as well, and some comments merely stated that there were no pressing needs at this time.
 Discussion
No less than four services were reported by CRPs as being provided in each of West Virginia’s counties listed. All nine CRP services were reported as being provided in all six WVDRS districts and in all West Virginia counties. At least two Pre-ETS services were reported by CRPs as being provided in each of the listed counties, with all five categories of Pre-ETS being reported as provided in all six WVDRS districts and in all West Virginia counties.
Over 95% of CRPs reported a Good or better rating of communication with WVDRS and no CRP rated communication with WVDRS as being Very Poor. This is somewhat contradictory with the fact that only 57.4% of the CRPs claimed that a WVDRS liaison counselor was in contact on a regular basis. This seems to indicate that communication does not have to be frequent, or even regularly occurring, in order to be good. Comments regarding communication (which were provided by nearly all respondents) reflected this at times, suggesting that communication was good when it occurred. At other times, comments indicated that the lack of regular communication was indeed a problem.
Comments on WVDRS improvement focused on referrals and improved communication. Transportation and service provision were also highlighted. Comments on CRP needs generally emphasized referrals, but also addressed service provision, transportation, and employer education.
Moving forward, as WVDRS continues providing services to individuals with the most significant disabilities, CRP services will continue to be a vital resource in helping these individuals attain their goal of competitive, integrated employment. WVDRS takes the feedback of its acknowledged vendors seriously and aims to make improvements, as needed, to facilitate relationships and performances with CRPs statewide.
CRP SERVICE RESPONSES FROM WVDRS FIELD STAFF SURVEY
CRP Service Need/Use
Service need/use for each service was assessed to allow respondents to indicate which services their consumers need/use most often. This was done independently of the service gap assessment as some services may be highly needed/used but are readily available, and therefore, do not require an increase in availability.
Employment and CRP services that were identified as needed by 50% or more of the total respondents are listed for each service category below with the percentage of respondents in parentheses:
•	Vocational Counseling & Guidance (76%)
•	Job Placement (68.9%)
•	Psychological Evaluation (68.3%)
•	Community-Based Assessment (67.1%)
•	Direct Placement by CRPs (66.5%)
•	Vocational Evaluation (64.7%)
•	Work Skills Assessment (63.5%)
•	Job Coaching other than SE (62.3%)
•	Work Adjustment Training (61.7%)
•	Job Development (59.3%)
•	Work-related tools/equipment (58.7%)
Service Gaps
Respondents that indicated a perceived service gap were totaled for each service.  The top five employment and CRP service gaps are listed for each service category below with percentage of respondents in parentheses:
•	Small Business Development (21.6%)
•	Direct Placement by CRPs (18.6%)
•	Job Development (17.4%)
•	Supported Employment (17.4%)
•	Trial Work Experience (17.4%)
c. Goals, Priorities, and Strategies
Section 101(a)(15) and (23) of the Rehabilitation Act require VR agencies to describe the goals and priorities of the State in carrying out the VR and Supported Employment programs. The goals and priorities are based on (1) the most recent CSNA, including any updates; (2) the State’s performance under the performance accountability measures of Section 116 of WIOA; and (3) other available information on the operation and effectiveness of the VR program, including any reports received from the SRC and findings and recommendations from monitoring activities conducted under Section 107 of the Rehabilitation Act. VR agencies must—
1. Describe how the SRC and the VR agency jointly developed and agreed to the goals and priorities and any revisions; and
The West Virginia Division of Rehabilitation Services (WVDRS) employs many goals to meet the needs of individuals with disabilities, particularly those individuals with the most significant disabilities. Furthermore, WVDRS recognizes those services essential to needs identified in the comprehensive assessment, evaluation of the Designated State Unit’s performance on the Workforce Innovation and Opportunity Act (WIOA) common performance measures to ensure quality services for individuals with significant disabilities, and services vital to the operation and effectiveness of the vocational rehabilitation (VR) program in West Virginia.
For the development of agency goals and priorities, WVDRS followed WIOA guidance in the development of the Combined State Plan. WVDRS worked closely with the WIOA core partners including WorkForce WV and the WV Adult Education. The WVDRS goals and priorities were developed to support the overall state goals and priorities in achieving a well-integrated workforce development system that provided customer-focused services to job seekers in West Virginia.
The West Virginia State Rehabilitation Council (SRC) maintained involvement throughout the development and assessment of agency goals and priorities in a variety of ways and provided WVDRS with valued input and recommendations. WVDRS executive managers, representatives of SRC, the West Virginia Statewide Independent Living Council (SILC), and the Client Assistance Program (CAP) were invited to discuss WVDRS goals and priorities for carrying out the VR and supported employment programs. The Executive Directors of the SRC and SILC attend monthly WVDRS Executive Management Group (EMG) meetings to discuss various ongoing issues affecting the agency and are privy to the current goals, objectives, and strategies pertaining to specific agency issues. Additional involvement occurs through WVDRS staff members attending SRC and SILC meetings to share information regarding agency performance, needs assessment, and State Plan activities. The SRC was afforded electronic access to the Program Year (PY) 2024 State Plan for review. The SRC members discuss WVDRS activities at regularly scheduled meetings and provide input to WVDRS.
2. Identify measurable goals and priorities in carrying out the VR and Supported Employment programs and the basis for selecting the goals and priorities (e.g., CSNA, performance accountability measures, SRC recommendations, monitoring, other information). As required in Section 101(a)(15)(D), (18), and (23), describe under each goal or priority, the strategies or methods used to achieve the goal or priority, including as applicable, description of strategies or methods that—
A. Support innovation and expansion activities;
B. Overcome barriers to accessing VR and supported employment services;
C. Improve and expand VR services for students with disabilities, including the coordination of services designed to facilitate the transition of such students from school to postsecondary life (including the receipt of VR services, post-secondary education, employment, and pre-employment transition services); and
D. Improve the performance of the VR and Supported Employment programs in assisting individuals with disabilities to achieve quality employment outcomes.
List and number each goal/priority, noting the basis, and under each goal/priority, list and number the strategies to achieve the goal/priority
At present, there is a labor supply shortage for the current and future demands for skilled workers in specific industries. Well-trained and qualified workers with disabilities are essential to meet the supply with the demand for qualified workers in targeted and growing industrial sectors to enable the state of West Virginia to achieve its maximum economic development potential. STEP21 has been WVDRS' strategy for the last two years, and it is designed to meet the mandates of WIOA and to satisfy West Virginia's labor needs. STEP21 requires all VR stakeholders (e.g., consumers, VR counselors, school counselors, special education teachers, parents, CRPs/service providers, etc.) to demand more and do more to enhance the system's service provision and its final outcomes of generating more well-qualified workers, especially those with disabilities. WVDRS and its WV Combined State Plan partners have been working together with the Governor's Office to develop a pipeline of qualified and needed workers for the in-demand jobs and industries for continuing economic growth and prosperity for the state and citizens of West Virginia. This belief is embedded in the Combined State Plan and the ways in which WVDRS has been and will be operating during the next 4-year period of PY24 to PY27. The new state goals and strategies of the Combined State Plan are consistent and parallel to WVDRS goals and priorities and will help prepare the state of West Virginia to experience economic growth and prosperity and improve the economic benefits of West Virginia workers, especially those with disabilities.
The workforce development system (WDS) of West Virginia believes that its successful activities positively contribute to the ongoing mission of increasing the labor force participation rate. The following are the current standing goals of the WDS, which will be updated when new WDS goals for Program Years 2024-2027 have been formally approved.
WDS Goal 1: Work-Based Learning
West Virginia will expand and implement high-quality work-based learning opportunities for youth and adult learners.
WDS Goal 2: Reduce Barriers to Sustainable Employment
West Virginia will increase referrals and integration of services to improve access to supportive services customized for individuals needing education and employment.
WDS Goal 3: Sector Strategies
West Virginia will implement comprehensive sector strategy approaches to reduce skills mismatches and enhance faster labor market attachment while informing education and training priorities.
WDS Goal 4: Integration and Innovation in Service Delivery
West Virginia will implement the Blue Ribbon Franchise Model of workforce service delivery to increase the efficiency of service delivery and effectiveness in serving businesses, workers, and job seekers.
It is an ongoing priority of WVDRS to ensure that all consumers have access to necessary services so they can meet their employment goals. Findings from the latest CSNA demonstrate the need for access to many services including transportation, psychological/psychiatric services, hearing/audiological services, and financial/tuition support. Presently, these services are being provided by WVDRS to consumers, as needed, so they can meet identified employment goals.
During FY 2023, the majority of WVDRS consumers were transition-aged youth, who were assisted with the college education services they needed to meet their employment-related education goals, as well as pre-employment transition services (Pre-ETS) to over 1,900 students with disabilities. WVDRS recognizes the importance of these services for consumers to obtain high-quality employment outcomes that will empower them to further their careers throughout their lifetimes. Additionally, WVDRS has specially trained rehabilitation counselors who work to meet the vocational rehabilitation needs of consumers who are deaf and hard of hearing. In FY 2023, WVDRS served more than 1,100 consumers with hearing impairments as their disability and spent more than $3.5 million on hearing-related services for these individuals.
WVDRS works diligently throughout the year to ensure access to all services needed by consumers. However, WVDRS and the SRC continue to emphasize the need to address access to transportation services as a specific goal because of the rural nature of West Virginia and how significantly this barrier to employment affects so many individuals with disabilities throughout the state.
WVDRS is fully committed to coordinate its activities and services with core and community partners to ensure successful completion of West Virginia's WDS goals. The following goals highlight specific focus areas for WVDRS that will also contribute to the overall goals of the West Virginia WDS:
WVDRS Goal 1 – Provide integrated vocational rehabilitation services to West Virginians with disabilities to promote attainment of a high school education or greater in order to increase their ability to move through meaningful career pathways.
•	Linked to WDS Goal 1: Work-Based Learning; WDS Goal 3: Sector Strategies; WDS Goal 4: Integration and Innovation in Service Delivery
In West Virginia, 58.2% of people 25 and older with disabilities have a high school degree or lower, compared to 44.1% of people without disabilities. Of those who have some college or above, 13.7% of people with disabilities graduate from college, compared to the 23.2% of people with disabilities who have some college experience or an associate degree. Meanwhile, the levels for people without disabilities are closer, 27.1% of that population have some college or associate degrees, while 27.1% have graduated from college. Close relationships with the WV Adult Education Program and the WV Higher Education Policy Commission, as well as State and local education agencies, will help to close this education gap.
Strategies and Methods
WVDRS will continue to monitor the educational achievement of all of its consumers, especially those in the transition youth (TY) population. Youth have become a primary focus in vocational rehabilitation and WVDRS will work closely and diligently with State and Local Education Agencies to ensure that its TY population receives the services that it needs, including pre–employment transition services (Pre- ETS) for students with disabilities. Each high school in WV has a WVDRS counselor assigned to it to guarantee the service provision of students with disabilities. A greater emphasis is now being placed for counselors to do outreach with these students and their parents/guardians during their freshman and sophomore years (rather than their junior year, as was formerly practiced) in order to maximize the counseling opportunities.
WVDRS counselors will continue to take part in the Individualized Education Program (IEP) development of students with disabilities when they are invited to do so. Counselors will also stay in contact with educators to discuss and resolve educational difficulties as they arise. WVDRS will also work closely with WV Adult Education, referring consumers as needed, to ensure that individuals with disabilities have an adequate opportunity to obtain a completed high school level education.
WVDRS Goal 1 Benchmark – For PY24 and PY25, WVDRS expects to achieve a credential attainment rate of 49% and 50% respectively. Additionally, we are going to increase the number of credentials attained by 5% each program year.
WVDRS Goal 2 – Provide Pre-Employment Transition Services (Pre-ETS) to students with disabilities.
•	Linked to WDS Goal 1: Work-Based Learning; WDS Goal 3: Sector Strategies; WDS Goal 4: Integration and Innovation in Service Delivery
Pursuant to requirements of WIOA and findings from the 2024 CSNA, WVDRS will, in cooperation with State and Local Education Agencies, provide Pre-ETS to students with disabilities, focusing on students 21 years or younger while still in high school. The provision of Pre-ETS offers students with disabilities information about careers, career opportunities, education and training programs, and self–advocacy. This information and work-based learning experiences can lead to more well-informed career decision making and can empower students with disabilities to become more educated and skilled, moving toward a career that meets their needs.
Strategies and Methods
The 2024 comprehensive statewide needs assessment (CSNA) indicated that job exploration counseling was the most frequently reported pre-employment transition service need. In accordance with this, and per the requirements of the Workforce Innovation and Opportunity Act (WIOA), WVDRS counselors in high schools will provide Pre-ETS to students with disabilities, especially job exploration counseling, in order to give students with disabilities and their parents/guardians a better understanding of labor market conditions, current and emerging career opportunities, and the necessary education and training requirements related to those opportunities.
WVDRS will continue to work closely with the WV Office of Special Education to ensure that special education teachers, parents, and students with disabilities are aware of the availability of Pre- ETS. This work will continue through joint-training conferences with special education staff from across the state. Additional, intensive training on the Pathways to the Future Pre-ETS website will also continue to be provided to special education teachers in upcoming years. As part of its outreach campaign, WVDRS will continue to place large banners in high schools and distribute Pre-ETS materials to students with disabilities across the state. Additional outreach using large posters will target eighth grade, career and technical education, and postsecondary students at locations across the state.
In addition to ongoing program activities, WVDRS will continue to sponsor the Career Exploration Opportunity (CEO) Summits, four-day summer workshops for students with disabilities statewide. The CEO Summits will be held in multiple locations across the state to ensure statewide coverage. WVDRS will utilize the assistance of Community Rehabilitation Programs (CRPs) to conduct the Summit activities. Class size for each of the Summits will be approximately 20 students. Students will earn a stipend for the time they attend. WVDRS will also request WorkForce WV and WV Adult Education to participate in the Summits to provide additional information to the students.
Topics to be covered:
•	Career planning
•	Career preparation
•	SSI/SSDI Information
•	Understanding the importance of necessary personal documents (e.g., social security card, driver’s license, birth certificate, pay stubs)
•	Communication
•	Conflict Management
•	Employer Expectations
•	Attendance and Punctuality
•	Timeliness of task completion
•	Be able to work without supervision
•	Positive work ethic
•	Manage multiple tasks
•	High–growth Jobs
•	Personal Brand
•	Job Hunting Tools – resumes, cover letters, interviews, and digital profiles
WVDRS Goal 2 Benchmark – WVDRS will increase the number of students receiving Pre-ETS services by 5% in each program year and will utilize at least 15% of vocational rehabilitation federal allocations for Pre-ETS each year.
WVDRS Goal 3 – Provide integrated vocational rehabilitation services to West Virginians with disabilities, committing to the use of the Employment First framework, to enable them to obtain competitive, integrated employment, especially in occupations and careers within emerging industries statewide.
•	Linked to WDS Goal 1: Work-Based Learning; WDS Goal 2: Reduce Barriers to Sustainable Employment; WDS Goal 3: Sector Strategies; WDS Goal 4: Integration and Innovation in Service Delivery
From a Bureau of Labor Statistics’ October 2023 report, West Virginia had the second lowest workforce participation rate (all individuals, with and without disabilities) among all the states and the District of Columbia, with 55.1% compared to the national average of 62.7%. Individuals with barriers to employment, including those with disabilities, have lower employment/workforce participation rates. Labor force participation among persons with disabilities in West Virginia has been steadily declining in recent years. Since 2010, labor force participation among these individuals is estimated to have fallen from 31.7% (63,609) to 29.7% (50,814) in 2021. As of 2021, labor force participation for persons with disabilities in West Virginia was 11 percentage points below the national rate of 40.7%. West Virginia has a high poverty rate, with 17.9% of residents below the poverty level compared to 11.5% nationally (https://www.census.gov/quickfacts/fact/table/US/IPE120222). The poverty rate is especially high for individuals with disabilities, with estimates that 31.3% of West Virginians with disabilities between the ages of 18-64 (53,491 of 171,095) were living in poverty in 2021, the 7th highest rate in the nation. excluding Puerto Rico. Even among those employed, there are still significant numbers of West Virginians who earn below the poverty line.
Workforce WV expects the largest numeric change in employment growth (from 2016 to 2026) to occur in the industries of Health Care and Social Assistance (+19,026; 14.94%), Ambulatory Health Care Services (+9,675; 23.90%), Educational Services (+4,498; 7.52%), Government (+3,996; 5.40%), Construction (+3,701; 12.36%), and Social Assistance (+3,507; 19.67%).
Strategies and Methods
Collaboration with WorkForce WV
WVDRS will maintain regular communication with WorkForce WV to stay abreast of trends in employment, including changes in education and training requirements. This will be accomplished through regular meetings of the workforce development system (WDS), written communications, teleconferences, and other media, as appropriate. WVDRS, particularly through its employment specialists, will also stay informed of emerging careers and occupations via WorkForce WV’s Labor Market Information website. WVDRS employment specialists continuously collect employment information from their business contacts. This information, including job orders for open positions, is immediately input into the WorkForce WV’s online Mid Atlantic Career Consortium (MACC) system and shared within the WDS.
WVDRS will continue to serve on Business Service Teams (BSTs) with WorkForce WV, Adult Education, local workforce development boards, and other related entities. Through training and standardizing informational materials, when possible, these teams provide a full range of WDS information when making visits to employers. This will allow the WDS to maximize the impact of employer visits and ensure that businesses are aware of all resources available through the WDS.
Use of WVDRS Employment Specialists
WVDRS will continue to use its employment specialists to gather information regarding employers at the local level, including information regarding job placements for individuals with disabilities and regarding current and expected employer needs.
WVDRS has an in-house Employer Services Section that specializes in providing employers with disability-related information, services, and pre-screened job seekers. The WVDRS Employer Services Section has nine employment specialists that cover all 55 counties in West Virginia. WVDRS’ team of employment specialists provide business owners and employers with critical business options and assistance in staffing, employee retention strategies, education on disability-related issues, job accommodations, and information about financial incentives for employers who hire individuals with disabilities.
Direct contact with employers is a key strategy to identify competitive integrated employment and career exploration opportunities for VR consumers, including students with disabilities.
Employment specialists, therefore, contact employers directly to identify current and future job openings. To facilitate this, WVDRS utilizes labor market information provided by WorkForce WV to identify the top employers in each county; contact is always made with the top ten employers in each county. When meeting with employers, employment specialists provide valuable information, including the WVDRS Employer Resource Guide and employment-related WorkForce WV information. The WVDRS Employer Resource Guide provides the following information:
•	Staffing services
•	Training programs and incentives for hiring people with disabilities
•	Financial incentives
•	Accessibility assessments
•	Accommodating employees with disabilities
•	Basic disability etiquette
•	Attitudinal barriers
•	Americans with Disabilities Act
•	Locating a WVDRS office
•	Where to find additional resources
The Employer Services Section maintains a database of each WVDRS–employer interaction with VR employment specialists. The information collected includes the business name, contact person, and current job openings by occupation. If needed, a referral to the WVDRS Rehabilitation Technology Unit is made to address workplace accommodations. This list is distributed to field staff to potentially match a job-ready VR consumer with a current job opening. Through positive working relationships, 47 employers, including some of the largest in the state, now send job postings directly to WVDRS’ Employer Services Section.
The Employer Services Section also works with employers to better serve transitioning youth with disabilities, including providing career exploration opportunities for students with disabilities. In 2015, WVDRS debuted the Positive Outcomes within Education and Rehabilitation (POWER) program. POWER is a job shadowing program that offers transitioning students, who may be having a difficult time choosing a career path, the opportunity to experience an occupation by spending time with a professional working in the students’ vocational goal/career field of interest. The POWER program allows the student the opportunity to experience an occupation prior to committing to training. It guides the student to take a serious, realistic look at the occupation, allowing the student to make a more informed choice.
Assistive Technology
WVDRS will continue to provide rehabilitation technology solutions to individuals with disabilities, as needed, so those individuals can become employed or maintain employment. WVDRS has developed working relationships and agreements for the coordination of activities with the West Virginia Assistive Technology System (WVATS) of the West Virginia University Center for Excellence in Disabilities. WVATS’ role is to provide access to and help with the acquisition of assistive technology (AT) devices and services for individuals with disabilities. WVATS also provides device demonstrations, device loans, training, AT information, and technical assistance.
WVDRS has a Rehabilitation Technology Unit which provides AT consultations and solutions to eligible VR consumers with AT needs throughout the state. With the coordination of services between WVDRS and WVATS, assurances are made that needed AT solutions can be provided to individuals with disabilities.
WVDRS Goal 3 Benchmark – WVDRS will continue to increase the number of consumers successfully closed in competitive integrated employment each program year.
Findings from the 2024 CSNA indicated the need to continue to improve VR services relating to the two most recently added WVDRS goals.
WVDRS Goal 4 – Improve access and availability of transportation options for WVDRS consumers who need transportation assistance to achieve or maintain competitive, integrated employment.
•	Linked to WDS Goal 2: Reduce Barriers to Sustainable Employment; WDS Goal 4: Integration and Innovation in Service Delivery
FY 2024 CSNA findings from field staff surveys indicate a need for continued efforts to increase the availability of transportation throughout the state. Based on responses by stakeholders across the state, including observations and recommendations by the WV State Rehabilitation Council, transportation continues to be an issue and a perceived barrier to employment/training. WVDRS continues to focus on individualized transportation solutions (ITS) to help alleviate the transportation gap while taking into account the wide array of circumstances that West Virginians with disabilities experience. WVDRS counselors also encourage consumers’ family members to assist with reimbursable transportation. WVDRS will continue to make sure that consumers are aware of these options and will continue to identify targeted solutions to the varied transportation issues for West Virginians with disabilities, focusing specifically on ITS.
Strategies and Methods
Transportation is an ongoing issue for West Virginians with disabilities, due to the rural nature of the state. A large proportion of the State’s inhabitants live far away from jobs, agency offices, and other resources. WVDRS continues its commitment to reduce transportation barriers for consumers with disabilities and to focus on individual transportation solutions (ITS) to satisfy immediate transportation needs. To help reduce these barriers, WVDRS counselors will encourage planning for transportation needs early in the development of a consumer’s rehabilitation program. At application, counselors will identify transportation issues and focus on finding solutions to include in the consumer’s Individualized Plan for Employment (IPE). This will ensure that the ability of consumers to reach their vocational goal is not impeded by preventable transportation barriers. Transportation issues also will be addressed by the standard instrument prescribed for routine use by supervisors and quality assurance staff in case reviews. Beyond ITS, WVDRS will continue to assign responsibility to a staff member in each branch office to maintain a list and working knowledge of local transportation options and will continue to participate in local and state initiatives to coordinate and expand transportation resources.
WVDRS Goal 4 Benchmark – WVDRS will continue to provide transportation services to more consumers each program year.
WVDRS Goal 5 – Continue to build collaborative relationships with community providers [including Community Rehabilitation Programs (CRPs), Independent Living, and other community providers] to enhance the availability of services to WVDRS consumers.
•	Linked to WDS Goal 2: Reduce Barriers to Sustainable Employment; WDS Goal 4: Integration and Innovation in Service Delivery
VR consumers require specialized services provided by CRPs statewide to achieve an integrated, competitive employment outcome. Responses from the CSNA indicate there still is a need for WVDRS to continue to improve collaborative relationships with all community providers. Findings from the CSNA point to a need to focus efforts on specific geographic areas within the state where miscommunication between community providers and WVDRS counselors continues. WVDRS will increase its focus on the provision of services for consumers with most significant disabilities under a Supported Employment Individualized Plan for Employment, especially for those who reside in rural areas.
Strategies and Methods
A large amount of the success that WVDRS has in its mission to enable and empower individuals with disabilities to work and to live independently hinges on its relationships with CRPs. In general, WVDRS has good working relationships with the various CRPs throughout the State. However, CSNA results suggest that improvements can be made, particularly in specific geographic areas. To facilitate this improvement, WVDRS has established a number of strategies to put into action:
•	Continue to educate field staff, especially the new counselors, about CRPs and their services. Use of the new ‘CRP Locator’ tool (a web-based, user-friendly vendor guide) and counselor CRP site visits will increase awareness of available service options, which will help to maintain collaborative relationships with CRPs and enhance the availability of services to WVDRS consumers.
•	Continue to maintain regular communications between WVDRS and community providers in each district and at the state level. Each WVDRS district will continue to host joint meetings with WVDRS district and branch office staff and CRPs in those districts to provide opportunities for CRP representatives and WVDRS personnel to discuss local service needs of WVDRS consumers, particularly to enhance service availability in rural areas. Subsequent to each meeting, the local WVDRS office will be required to send a brief report to the CRP Program Manager. This process will allow all parties involved in the expansion of community-based services to be kept informed of progress and issues. WVDRS will continue to examine the information and recommendations collected from various meetings between CRP and WVDRS staff members.
•	Increase focus on the provision of services for consumers with most significant disabilities under a Supported Employment Individualized Plan for Employment, especially for those who reside in rural areas.
Progress on communication will continue to be made as the WVDRS acquires more understanding of the issues and barriers facing the CRP and WVDRS staff members in their service provision to persons with significant disabilities in WV. Ongoing communication activities with CRPs also will include:
•	An email listserv with all current vendors that will be updated periodically and utilized to send out training opportunities, policy changes, and general updates when needed.
•	WVDRS counselors in each district will continue to be assigned as liaisons to each CRP and will continue to be required to complete a monthly update regarding the CRP. They will collect this information by visits and/or phone calls. Having CRP liaisons that regularly discuss service-related issues specific to the local service area(s) will aid in maintaining collaborative working relationships and enhancing the availability of services to consumers.
•	Two rehabilitation specialists covering all districts in the state will provide technical assistance to CRPs and WVDRS staff. They will make site visits to CRP and WVDRS district and branch offices. During these visits, they will provide technical assistance and schedule training and other meetings that need to occur. They will serve as a communication link when issues arise and make themselves available to attend the communication meetings and transition team meetings.
•	Conduct site visits to ensure that community providers continue to meet WVDRS standards and requirements.
•	Increase the service provision of acknowledged vendors and work with community providers to expand their service areas to enhance the availability of community services within needed areas.
•	Continue to conduct Transition Team meetings at the district level with WVDRS, WV Department of Education, and CRP staff members. The meetings will be held to promote interagency collaboration by allowing staff from each agency/CRP to become familiar with the different eligibility requirements and service definitions across agencies.
•	Continue to conduct cross training and face-to-face meetings with community partners at the local level.
•	Continue to assign liaison responsibilities to staff members and provide them guidance about the purpose of WVDRS participation in community events.
•	Monitor the WVDRS counselors/supervisors/managers’ perception of the quality of CRP services through a survey instrument.
•	Monitor and assess the impact of the Quality Assurance Unit on the counselor’s case management practices by using data generated from the quality assurance specialists’ review of cases.
WVDRS Goal 5 Benchmark – WVDRS will maintain quarterly meetings with CRPs, and other service providers, as appropriate, at the district level.
For the development of agency goals and priorities, WVDRS followed WIOA guidance in the development of the Combined State Plan. WVDRS worked closely with the WIOA core partners, including WorkForce WV and WV Adult Education. The WVDRS goals and priorities were developed to support the overall state goals and priorities in achieving a well-integrated workforce development system that provided customer-focused services to job seekers in West Virginia.
The West Virginia SRC maintained involvement throughout the development and assessment of agency goals and priorities in a variety of ways and provided WVDRS with valued input and recommendations. WVDRS executive managers, representatives of SRC, the West Virginia SILC, and the CAP were invited to discuss WVDRS goals and priorities for carrying out the VR and supported employment programs. The Executive Directors of the SRC and SILC attend monthly WVDRS EMG meetings to discuss various ongoing issues affecting the agency and are privy to the current goals, objectives, and strategies pertaining to specific agency issues. Additional involvement occurs through WVDRS staff members attending SRC and SILC meetings to share information regarding agency performance, needs assessment, and State Plan activities. The SRC was afforded electronic access to the PY 2024 State Plan for review. The SRC members discuss WVDRS activities at regularly scheduled meetings and provide input to WVDRS.
To foster a customer-focused approach to VR services, WVDRS works with the WV State Rehabilitation Council and Statewide Independent Living Council and uses Innovation and Expansion (I&E) resources to support the activities of these groups. As appropriate, WVDRS will continue to use I&E funds to discover, generate, and improve upon service delivery processes to individuals with disabilities. Additionally, with the emphasis on Pre-ETS to students with disabilities now in place by WIOA, there are significant opportunities for discoveries that can be made using I&E resources.
WVDRS acknowledges the legal requirement to report on the performance accountability indicators under Section 116 of WIOA. However, data collection on the performance accountability indicators is only beginning, making a full report of WVDRS performance impossible at this time. As WVDRS moves forward in its task to place individuals with disabilities into competitive, integrated employment in PY 2024, it will continue to collect and monitor participant data to generate reports on:
•	The percentage of program participants who are in unsubsidized employment during the second quarter after exit from the program;
•	The percentage of program participants who are in unsubsidized employment during the fourth quarter after exit from the program;
•	The median earnings of program participants who are in unsubsidized employment during the second quarter after exit from the program;
•	The percentage of program participants who obtain a recognized postsecondary credential, or a secondary school diploma or its recognized equivalent, during participation in or within 1 year after exit from the program;
•	The percentage of program participants who, during a program year, are in an education or training program that leads to a recognized postsecondary credential or employment and who are achieving measurable skill gains toward such a credential or employment; and
•	The indicators of effectiveness in serving employers.
For PY 2022, WVDRS achieved the following performance on the performance accountability indicators under section 116 of WIOA:
•	The percentage of program participants who are in unsubsidized employment during the second quarter after exit from the program – 72.8%
•	The median earnings of program participants who are in unsubsidized employment during the second quarter after exit from the program – $7,063
•	The percentage of program participants who are in unsubsidized employment during the fourth quarter after exit from the program – 70.1%
•	The percentage of program participants who obtain a recognized postsecondary credential, or a secondary school diploma or its recognized equivalent, during participation in or within 1 year after exit from the program – 48.8%
•	The percentage of program participants who, during a program year, are in an education or training program that leads to a recognized postsecondary credential or employment and who are achieving measurable skill gains toward such a credential or employment – 46.3%
d. Evaluation and Reports of Progress: VR and Supported Employment Goals
For the most recently completed program year, provide an evaluation and report of progress for the goals or priorities, including progress on the strategies under each goal or priority, applicable to that program year. Sections 101(a)(15) and 101(a)(23) of the Rehabilitation Act require VR agencies to describe—
1. Progress in achieving the goals and priorities identified for the VR and Supported Employment Programs;
List the goals/priorities and discuss the progress or completion of each goal/priority and related strategies
The following description includes progress in the achievement of the goals for the West Virginia Division of Rehabilitation Services (WVDRS).
WVDRS Goal 1 – Provide integrated vocational rehabilitation (VR) services to West Virginians with disabilities to enable them to attain a high school education or greater.
Compared to the national average of 33.7%, West Virginia has a much lower percentage of individuals 25 years and older having attained a bachelor’s degree (21.8%; from https://www.census.gov/quickfacts/fact/table/WV,US/EDU685221). For individuals with disabilities, the percentage is much lower, at 7.3% (from the Annual Disability Statistics Compendium: 2023). While a majority (80.2%) of West Virginians with disabilities age 25 or over have a high school education or higher, nearly one-fifth (19.8%) of this population does not, compared to only 8.3% of the State’s population of 25 or older without a disability (Annual Disability Statistics Compendium: 2023). Close relationships with the WV Adult Education Program (Adult Ed) and the WV Higher Education Policy Commission, as well as State and Local Education Agencies, will help to close this education gap.
WVDRS has worked hard to strengthen its relationship with State and Local Education Agencies and has sought to increase its service capacity to students with disabilities statewide. This includes formal agreements and Memorandums of Understanding (MOUs), the provision of Pre- employment Transition Services (Pre-ETS) in and outside of school settings, the continuation of WVDRS’ Student Transition to Employment Program (STEP) and coordinated training with Special Education teachers statewide.
WVDRS monitored the educational achievement of all of its consumers, especially those in the transition youth (TY) population. WVDRS worked closely and diligently with State and Local Education Agencies to ensure that its TY population receives the services that it needs, including pre-employment transition services for high school students with disabilities. WVDRS assigned a counselor to each high school in WV to enhance the service provision of students with disabilities. A greater emphasis is now being placed for counselors to do outreach with these students and their parents/guardians during their sophomore year (rather than their junior year, as was formerly practiced) in order to maximize the counseling opportunities.
WVDRS counselors took part in the Individualized Education Program (IEP) development of students with disabilities when invited to do so. Counselors stayed in contact with educators to discuss and resolve educational difficulties as needed. WVDRS also worked closely with WV Adult Education, referring consumers as needed, to ensure that individuals with disabilities have an adequate opportunity to obtain a completed high school level education. WVDRS will continue to conduct these activities as part of its progress toward achievement of this goal.
WVDRS Goal 2 – Provide Pre-ETS to students with disabilities.
WVDRS has demonstrated considerable commitment to providing Pre-ETS to students with disabilities statewide since the implementation of WIOA.  WVDRS established, and regularly enhances, the Pathways to the Future website (www.pathwayswv.org), designed to operate as a self-service one-stop for students, parents, and educators in the provision of Pre-ETS that can be accessed at any time. The site provides extensive information and resources regarding career planning, education planning, independent living skills, self-determination, and work-based learning.
Beyond this self-service portal, WVDRS has been active, both within and outside of school settings to ensure that students with disabilities statewide receive the Pre-ETS needed to promote a more well-informed student base regarding employment, career pathways, independent living and soft skills, and self-advocacy. Numerous initiatives and activities, provided by WVDRS staff, Education staff, and Community Rehabilitation Programs (CRPs), have been delivered to thousands of students across the state in all 55 counties. In doing so, WVDRS has consistently been able to successfully reserve and spend the WIOA-mandated 15% earmark of federal funds on Pre-ETS. Some of the activities conducted by the agency include:
•	Career Exploration Opportunities (CEOs) – provides participants with information about career planning and preparation, self-assessments, completing job applications, interviewing skills, how to dress for employment, work ethic, cell phone and Internet safety, and self-advocacy. The service is a total of 24 hours, typically completed in 4 days with 6 hours of service each day. The service is provided in a group setting (maximum of 25 participants) and can be completed in person or virtually.
•	Instruction in Self-Advocacy programs (ISAs) – provides participants with information about self-awareness, IDEA, Section 504, ADA, IEPs, centers for independent living, college accessibility offices, accommodations, and communication skills. The service is a total of 24 hours, typically completed in 4 days with 6 hours of service each day. The service is provided in a group setting (maximum of 25 participants) and can be completed in person or virtually.
•	Postsecondary Education Opportunities (PSEOs) – provides participants with counseling on post-secondary educational opportunities by coordinating structured day visits (up to 8 hours) to campuses of Colleges and Universities, Career and Technical Education, or other Vocational/Adult Educational Facilities.
•	Positive Outcomes Within Education and Rehabilitation (POWER) program – WVDRS’ job shadowing program. POWER offers WVDRS transition students who are interested in professional careers an opportunity to spend a few hours or a day with a skilled worker in the student’s vocational field of interest, allowing the student to explore a specific career of interest by observing an employee perform his or her work duties at his or her place of employment. The experience should provide realistic career information that will aid the student in making career choices.
•	Work-Based Learning Experiences – Provided in conjunction with CRPs to pair students with disabilities with local employers willing to provide short-term work experiences to assist in developing an understanding of the demands of paid work, improvement of soft skills needed to be successful in any employment setting and assist in better understanding of career choices.  Students complete the experience after a maximum of 40 work hours, over the course of 60 days, earning no less than minimum wage. The CRPs are paid to arrange and monitor the experience, as well as pay the students.
The 2024 comprehensive statewide needs assessment (CSNA) indicated that job exploration counseling continues to be the most frequently reported pre–employment transition service need. In accordance with this, and per the requirements of the Workforce Innovation and Opportunity Act (WIOA), WVDRS counselors in high schools provided, through purchased and direct services,  Pre-ETS to students with disabilities, especially job exploration counseling, in order to give students with disabilities and their parents/guardians a better understanding of labor market conditions, current and emerging career opportunities, and the necessary education and training requirements related to those opportunities.  In PY 2022, WVDRS provided Pre-ETS to over 1,500 students with disabilities.
Throughout the academic year, WVDRS Employment Specialists also provided Pre-ETS in virtual and in person formats. The Employment Specialists conducted mock interviewing, career exploration, and other employment related topics. The POWER program provides students an opportunity to job shadow careers that they are interested in. The Employment Specialists have worked to identify a vast array of employers located throughout the State. There are currently 85 employers involved in the POWER Program.
WVDRS’ “Pathways to the Future” website (www.pathwayswv.org), serves as a self-service resource for students with disabilities statewide to receive Pre-ETS.  The website provides valuable information and tools regarding career planning, education planning, independent living, self-determination, and work-based learning. The website was bolstered by banners that were placed in high schools in all 55 counties of the state. Additionally, several pages of the College Foundation of West Virginia’s website (www.cfwv.com) have links to the Pathways website. These banners and links directed students with disabilities to the website and its resources.
WVDRS Goal 3 – Provide integrated vocational rehabilitation services to West Virginians with disabilities to enable them to obtain competitive employment, especially in occupations and careers within emerging industries statewide.
With the passage of WIOA, WVDRS has made several adjustments to its service provision model, including a greater emphasis toward youth and students with disabilities. In Program Year (PY) 2022, WVDRS served 12,362 participants, including 8,305 youth with disabilities, while enabling 1,809 job seekers with disabilities to obtain or retain employment.
Collaboration with WorkForce WV and Local Workforce Development Boards
WVDRS has maintained regular communication with WorkForce WV to stay abreast of trends in employment, including changes in education and training requirements. This has been accomplished through regular meetings of the Workforce Development System (WDS), written communications, teleconferences, and other media. WVDRS, particularly through its Employment Specialists, stayed informed of emerging careers and occupations via WorkForce WV’s Labor Market Information website. WVDRS Employment Specialists have also continuously collected employment information from their business contacts. This information is shared within the WDS. WVDRS registers its job-ready consumers with WorkForce WV in order to better serve employers by providing them with a base of potential employees.
WVDRS maintained and continues to maintain a presence with each of West Virginia’s seven Local Workforce Development Boards (WDBs): Region 1 WDB; Region 2 – South Western WV WDB, Inc.; Region 3 – WDB of Kanawha County, Inc.; Region 4 Mid-Ohio Valley WDB; Region 5 – Northern Panhandle WDB; Region 6 WDB, and Region 7 WDB. WVDRS has signed MOUs and Infrastructure Funding Agreements (IFAs) with each board. Each Local WDB has a WVDRS representative who is active in the Board’s activities and decision-making process.
Use of WVDRS Employment Specialists
WVDRS used its Employment Specialists to gather information regarding employers at the local level, including information regarding job placements for individuals with disabilities and regarding current and expected employer needs.
WVDRS has an in-house Employer Services Section that specializes in providing employers with disability-related information, services, and pre-screened job seekers. The WVDRS Employer Services Section has nine Employment Specialists that cover all 55 counties in West Virginia. Each Employment Specialist has a unique understanding of local labor market information (LMI) including what jobs are available, what jobs are in demand or decline, and employer networks.
WVDRS’ team of Employment Specialists provided business owners and employers with critical business options and assistance in staffing, employee retention strategies, education on disability- related issues, job accommodations, and information about financial incentives for employers who hire individuals with disabilities.
Direct contact with employers is a key strategy to identify competitive integrated employment and career exploration opportunities for VR consumers, including students with disabilities.
Employment Specialists therefore contact employers directly to identify current and future job openings. To facilitate this, WVDRS utilizes labor market information provided by WorkForce WV to identify the top employers in each county; contact is always made with the top ten employers in each county. When meeting with employers, Employment Specialists provide valuable information, including the WVDRS Employer Resource Guide. The resource guide provides information regarding staffing services, training programs and incentives for hiring people with disabilities, financial incentives, accessibility assessments, accommodating employees with disabilities, basic disability etiquette, attitudinal barriers, the Americans with Disabilities Act, locating a WVDRS office, and where to find additional resources. WVDRS Employment Specialists provided various services and over 500 employer visits in Program Year 2022.
The Employer Services Section maintains a database of each WVDRS-employer interaction with VR employment specialists. The information collected includes the business name, contact person, and current job openings by occupation. If needed, a referral to the WVDRS Rehabilitation Technology Unit is made to address workplace accommodations. This list is distributed to Counselors to potentially match a job-ready VR consumer with a current job opening. Through positive working relationships, 47 employers, including some of the largest in the state, now send job postings directly to WVDRS’ Employer Services Section.
The Employer Services Section also worked with employers to better serve transitioning youth with disabilities, including providing career exploration opportunities for students with disabilities through the POWER program. POWER is a job shadowing program that offers transitioning students, who may be having a difficult time choosing a career path, the opportunity to experience an occupation by spending time with a professional working in the students’ vocational goal/career field of interest. The POWER program allows the student the opportunity to experience an occupation prior to committing to training. It guides the student to take a serious, realistic look at the occupation, allowing the student to make a more informed choice. Currently, there are 85 employers statewide that participate in the POWER program.
Assistive Technology (AT)
WVDRS will continue to provide rehabilitation technology and AT solutions to individuals with disabilities, as needed, so those individuals can participate in training programs in addition to gaining or maintaining competitive, integrated employment. These services are provided directly by WVDRS staff as well as purchased from various service providers.
WVDRS’ Rehabilitation Technology Unit provides AT consultations and solutions to eligible VR consumers with AT needs statewide. WVDRS is working on maintaining its own supply of commonly used AT equipment to have on-hand when needed by a consumer. This will enable consumers (especially students with disabilities) to continue towards successfully completing their individualized plans for education, training and/or employment without interruption. WVDRS will maintain this AT equipment supply at different strategic locations in the state.
WVDRS has developed working relationships and agreements for the coordination of activities with the West Virginia Assistive Technology System (WVATS) of the West Virginia University Center for Excellence in Disabilities to maximize available resources. WVATS’ role is to provide access to and help with the acquisition of assistive technology (AT) devices and services for individuals with disabilities. WVATS also provides device demonstrations, device loans, training, AT information, and technical assistance.
WVDRS Goal 4 – Improve access and availability of transportation options at the community level for WVDRS consumers who need transportation assistance to achieve or maintain competitive, integrated employment.
WVDRS continues to work toward finding individualized transportation solutions for West Virginians with disabilities as needed for their employment goals In Program Year (PY) 2022, WVDRS expended $461,361 on transportation services for 258 consumers. In recent years, the agency has provided more comprehensive individualized transportation solutions, including the purchase of pre-owned vehicles and vehicle modifications, when appropriate.  While this has increased the average cost per consumer, due to the rural nature of the state, these individualized solutions are critical to ensuring VR consumers obtaining and/or maintaining competitive integrated employment.
Transportation is an ongoing issue for West Virginians with disabilities, due to the rural nature of the state. A large proportion of the State’s inhabitants live far away from jobs, agency offices, and other resources. WVDRS continued its commitment to reduce transportation barriers for consumers with disabilities and focused on Individual Transportation Solutions (ITS) to satisfy immediate transportation needs. To help reduce these barriers, WVDRS counselors encouraged planning for transportation needs early in the development of a consumer’s rehabilitation program. At application, counselors identified transportation issues and focused on finding solutions to include in the consumer’s Individualized Plan for Employment (IPE). This ensured that the ability of consumers to reach their vocational goal was not impeded by preventable transportation barriers. Transportation issues were also addressed by the standard instrument prescribed for routine use by supervisors and quality assurance staff in case reviews. Beyond ITS, WVDRS continued to assign responsibility to a staff member in each branch office to maintain a list and working knowledge of local transportation options and continued to participate in local and state initiatives to coordinate and expand transportation resources. These activities will be ongoing as WVDRS strives to accomplish transportation access for all of its consumers in need.
WVDRS Goal 5 – Continue to build collaborative relationships with community providers (including CRPs, Independent Living, and other community providers) to enhance the availability of services to WVDRS consumers.
A comparison of findings from the 2021 CSNA and the 2024 CSNA indicates that there is still a need to continue to improve collaborative relationships with community providers. A smaller percentage of CRP survey respondents acknowledged that a WVDRS liaison counselor was in contact on a regular basis (i.e., 71.4% in 2021 vs. 57.4% in 2024). However, there was an increase in the percentage of CRP survey respondents who rated their communication with WVDRS to be good or better (87.5% in 2021 vs. 95.1% in 2024).
2021 - Forty out of the 42 CRPs provided a rating of their communication with WVDRS.  Options ranged from excellent to very poor. No CRP gave a rating of very poor and 35 of the 40 CRPs (87.5%) gave a response of good or better.  When asked whether a WVDRS liaison counselor was in contact on a regular basis, 30 of 42 CRPs responded yes, while 10 CRPs responded no (71.4% and 23.8%, respectively). Two CRPs did not respond to this question
2024 – All 61 CRP respondents provided a rating of their communication with WVDRS. Options ranged from excellent to very poor.  No CRP gave a rating of very poor and 58 of the 61 CRPs (95.1%) gave a response of good or better. When asked whether a WVDRS liaison counselor was in contact on a regular basis, 35 of 61 CRPs responded yes, while 26 CRPs responded no (57.4% and 42.6%, respectively). All respondents answered this question.
WVDRS continues to utilize CRPs to provide services to its consumers.  In PY 2022, WVDRS authorized over $2,500,443 in CRP services to 1,197 consumers.
WVDRS continued to educate field staff, especially new counselors, about CRPs and their services. Use of the new ‘CRP Locator’ tool (a web-based, user-friendly, vendor guide) and counselor CRP site visits increased awareness of available service options, which helped to maintain collaborative relationships with CRPs and enhance the availability of services to WVDRS consumers. WVDRS continued to maintain regular communications with community providers in each district and at the state level. Progress on communication will continue to be made as the Division acquires more understanding of the issues and barriers facing the CRP and WVDRS staff members in their service provision to persons with significant disabilities in WV.
Ongoing communication activities with CRPs also includes:
1.	An email listserv with all current vendors that is updated periodically and utilized to send out training opportunities, policy changes, and general updates when needed.
2.	WVDRS counselors in each district continue to be assigned as liaisons to each CRP and continue to be required to complete a monthly update regarding the CRP. They collect this information by visits and/or phone calls. Having CRP liaisons that regularly discuss service-related issues specific to the local service area(s) aids in maintaining collaborative working relationships and enhancing the availability of services to consumers.
3.	Two Rehabilitation Specialists covering all districts in the state provide technical assistance to CRPs and WVDRS staff. They make site visits to CRP and WVDRS district and branch offices to ensure that community providers continue to meet WVDRS standards and requirements. During these visits, they provide technical assistance and schedule training and other meetings that need to occur. They serve as a communication link when issues arise and make themselves available to attend communication meetings and transition team meetings.
Additionally, the agency works to:
•	Increase the service provision of acknowledged vendors and work with community providers to expand their service areas to enhance the availability of community services within needed areas.
•	Conduct Transition Team meetings at the district level with WVDRS, WV Department of Education, and CRP staff members. The meetings are held to promote interagency collaboration by allowing staff from each agency/CRP to become familiar with the different eligibility requirements and service definitions across agencies.
•	Conduct cross training and face-to-face meetings with community partners at the local level.
•	Assign liaison responsibilities to staff members and provide guidance about the purpose of WVDRS participation in community events.
•	Monitor the WVDRS counselors/supervisors/managers’ perception of the quality of CRP services through a survey instrument; and
•	Monitor and assess the impact of the Quality Assurance unit on the counselor’s case management practices by using data generated from the quality assurance specialists’ review of cases.
In Program Year 2022, WVDRS authorized $625,497 in CRP Supported Employment (SE) services for 236 consumers with the most significant disabilities.
As previously addressed in the discussion of WVDRS Goal 5, WVDRS continued to build collaborative relationships with community providers (including CRPs, Independent Living, and other community providers) to enhance the availability of services to WVDRS consumers. A comparison of findings from the 2021 CSNA and the 2024 CSNA indicates that there is still a need to continue to improve collaborative relationships with community providers. A smaller percentage of CRP survey respondents acknowledged that a WVDRS liaison counselor was in contact on a regular basis (i.e., 71.4% in 2021 vs. 57.4% in 2024) and an increase in the percentage of CRP survey respondents rated their communication with WVDRS to be Good or better (87.5% in 2021 vs. 95.1% in 2024).
2. Performance on the performance accountability indicators under Section 116 of WIOA for the most recently completed program year, reflecting actual and negotiated levels of performance. Explain any discrepancies in the actual and negotiated levels; and
As WVDRS moves forward in its task to place individuals with disabilities into competitive, integrated employment in PY 2023, it will continue to collect and monitor participant data in order to generate reports on:
•	The percentage of program participants who are in unsubsidized employment during the second quarter after exit from the program.
•	The percentage of program participants who are in unsubsidized employment during the fourth quarter after exit from the program.
•	The median earnings of program participants who are in unsubsidized employment during the second quarter after exit from the program.
•	The percentage of program participants who obtain a recognized postsecondary credential, or a secondary school diploma or its recognized equivalent, during participation in or within 1 year after exit from the program.
•	The percentage of program participants who, during a program year, are in an education or training program that leads to a recognized postsecondary credential or employment and who are achieving measurable skill gains toward such a credential or employment; and
•	The indicators of effectiveness in serving employers.
For PY 2022, WVDRS achieved the following performance on the performance accountability indicators under section 116 of WIOA:
•	The percentage of program participants who are in unsubsidized employment during the second quarter after exit from the program – 72.8% (negotiated level for PY 2022– 64%)
•	The median earnings of program participants who are in unsubsidized employment during the second quarter after exit from the program – $7,063 (negotiated level for PY 2022– $5,371%)
•	The percentage of program participants who are in unsubsidized employment during the fourth quarter after exit from the program – 70.1% (negotiated level for PY 2022– 61.6%)
•	The percentage of program participants who obtain a recognized postsecondary credential, or a secondary school diploma or its recognized equivalent, during participation in or within 1 year after exit from the program – 48.8% (negotiated level for PY 2022– 44.2%)
•	The percentage of program participants who, during a program year, are in an education or training program that leads to a recognized postsecondary credential or employment and who are achieving measurable skill gains toward such a credential or employment – 46.3% 
•	WVDRS recognizes the importance of measurable skill gain (MSG). Since WVDRS was unable to meet the latest negotiated level of MSG, WVDRS will take necessary steps to improve performance levels on the MSG rate. WVDRS will work with staff, consumers, and partners to implement the following actions:	
o	Increase training for vocational counselors on measurable skill gains, including what they are, documentation requirements, and the content and process of the conversations to have with students regarding documentation needed to complete an MSG.
o	Increase the reminders and pre-warning indicators of the current case management system to ensure counselors are aware of MSG requirements.
o	Increase the frequency of collection of MSG information from consumers during the year.
o	Employ supervision validation. MSG data will be consistently reviewed to ensure the necessary documentation needed for MSG are being collected and reported. This will also confirm accurate information for the purpose of RSA 911 reporting.
•	The indicators of effectiveness in serving employers – N/A (baseline data collection is still ongoing)
3. The use of funds reserved for innovation and expansion activities (Sections 101(a)(18) and 101(a)(23) of the Rehabilitation Act) (e.g., SRC, SILC).
WVDRS fully embraces the Congressional intent that individuals with disabilities and their advocates are full partners in the state rehabilitation program. Therefore, WVDRS has established a goal to improve its service delivery system through involvement of consumers and their advocates to increase the ease of access to, timeliness of, and quality of rehabilitation services and ultimately to improve employment outcomes for individuals with disabilities. The Division’s concentration of I&E efforts on consumer partnerships demonstrates its commitment to enhanced consumer involvement.
Success in working with consumers and their advocates is fundamentally important in developing and using innovative approaches to achieve long–term success in expanding and improving rehabilitation services, including supported employment. WVDRS pursues that work primarily through partnership initiatives with the West Virginia State Rehabilitation Council (WV SRC) and the West Virginia Statewide Independent Living Council (SILC).
WVDRS believes that the activities of these councils provide a promising foundation for the kind of partnership envisioned by the Rehabilitation Act Amendments of 1998. If that partnership is to achieve its full potential, however, it must receive the necessary support.
Therefore, WVDRS annually allocates I&E funds to support general operations of the WV SRC and the SILC.
Program Year (PY) 2022 highlights for each appear below. WEST VIRGINIA STATE REHABILITATION COUNCIL
I&E funds support operations and activities undertaken by members of the WV SRC, as mandated by WIOA. WVDRS allocated $52,168 for WV SRC in PY 2022.
As required by the Rehabilitation Act Amendments of 1998, WV SRC assists WVDRS by conducting a survey of consumer satisfaction for WVDRS consumers whose VR cases have been closed. Surveys were mailed to approximately 3,379 individuals in PY 2022. WV SRC uses I&E funds to share costs of contracting an independent consultant to compile a report of survey results.
I&E funding assists WV SRC to prepare, publish, and distribute its annual report.
WV SRC also participates in development and establishment of WVDRS goals and priorities outlined in this state plan. I&E funds are used for travel costs as necessary.
WEST VIRGINIA STATEWIDE INDEPENDENT LIVING COUNCIL
In combination with Title VII money, I&E funds help support operations and activities undertaken by the SILC. WVDRS allocated $228,900 for the SILC in PY 2022.
The SILC, in partnership with WVDRS, jointly develops and submits the State Plan for Independent Living (SPIL), as appropriate. The SILC continues to monitor and evaluate the implementation and effectiveness of the SPIL. In conjunction with WVDRS, the SILC prepares and submits the 704 Report for West Virginia.
SILC members and/or employees collaborate with and/or participate in activities of the WV Centers for Independent Living (WVCIL), WV Developmental Disabilities Council, WV SRC, WV Olmstead Council, WV Mental Health Consumers Association, WV American Association of Retired Persons (AARP), Medley Hartley Advocacy Project Advisory Council, WV Transportation Alliance, and the Fair Shake Network. Training for service providers on sexual victimization of individuals with disabilities has been scheduled.
The SILC conducts a survey of consumer satisfaction for consumers who received independent living services. The SILC uses I&E funds to share costs with WVDRS and WVCIL for distribution of the survey and contracting an independent consultant to compile survey results and prepare an annual report of findings.
The SILC ensures that all meetings are open to the public and provides notice through the WV Secretary of State’s Office as well as through statewide media at least two weeks prior to the meetings.
 
e. Supported Employment Services, Distribution of Title VI Funds, and Arrangements and Cooperative Agreements for the Provision of Supported Employment Services.
1. Acceptance of title VI funds:
(A) VR agency requests to receive title VI funds.
2. If the VR agency has elected to receive title VI funds, Section 606(b)(3) of the Rehabilitation Act requires VR agencies to include specific goals and priorities with respect to the distribution of Title VI funds received under Section 603 of the Rehabilitation Act for the provision of supported employment services. Describe the use of Title VI funds and how they will be used in meeting the goals and priorities of the Supported Employment program.
The methodology of the West Virginia Division of Rehabilitation Services (WVDRS) for distribution of Title VI-B funds is based exclusively on a fee-for-service authorization process with approved vendors of supported employment (SE) services. WVDRS uses no Title VI-B funds for administrative costs. Utilizing the WVDRS fee schedule for SE services, rehabilitation counselors utilize Title VI-B and Title I funds to provide needed SE services for eligible individuals with the most significant disabilities.
WVDRS established a statewide fee–for–service funding approach for job development services for SE-eligible individuals. This structure provides vendors an effective and efficient way of meeting the costs of this critical element of the job placement process. The process provides reimbursement for employment outcomes and brings increased energy and vendor resources to support job development activities.
In Program Year 2022, WVDRS authorized $358,806 of its Title VI-B funds to serve individuals with the most significant disabilities in its SE program through community rehabilitation program (CRP) services. When Title VI-B funds ($300,000 total per year with $150,000 available only for youth with disabilities) are exhausted, WVDRS defrays supported employment program service costs with Title I funds for individuals who require the services or who qualify and have not yet been served under the supported employment program. In Program Year 2022, WVDRS authorized $247,949 in SE services for 113 adults with disabilities and $548,103 in SE services for 159 youth with disabilities.
WVDRS plans to continue using three prevalent models of supported employment services: individual placement, mobile work crews, and enclaves. Additionally, WVDRS will encourage and support development of affirmative industries that integrate workers with disabilities and workers without disabilities throughout the CRP network.  WVDRS considers each placement on an individualized, case-by-case basis to ensure the placement setting meets the definition of an integrated employment setting. For consumers with the most significant disabilities in supported employment, WVDRS strives for each consumer to achieve a competitive, integrated employment outcome.
WVDRS policies defining competitive employment settings promote linking CRPs with federal and state work contracts that may exist within the community. Such links expand job opportunities for individuals receiving SE, particularly those who reside in rural locations. This approach also directs Title VI-B and Title I funds into placement-related services and activities.
As appropriate, WVDRS will use the State funds allocated ($78,000) for ESES to expand employment opportunities for youth with the most significant disabilities (MSD). WVDRS will continue to educate the legislature regarding ESES for youth with MSD to ensure continued funding for ESES.
3. Supported employment services may be provided with Title 1 or Title VI funds following placement of individuals with the most significant disabilities in employment. In accordance with Section 101(a)(22) and Section 606(b)(3) of the Rehabilitation Act, describe the quality, scope, and extent of supported employment services to be provided to individuals with the most significant disabilities, including youth with the most significant disabilities; and the timing of transition to extended services.
The West Virginia Division of Rehabilitation Services (WVDRS) vendor acknowledgment process includes an in-service training session for prospective new vendors and training updates as requested. During the training session, participants receive a Service Provider Guide and an introduction to the WVDRS process for providing supported employment (SE) services. WVDRS also loans SE training books and materials at no cost.
The quality of SE services is directly tied to the competency of the personnel performing job development and community-based training services. WVDRS encourages and supports the provision of a broad range of in-service training programs for personnel directly involved in SE service delivery.
WVDRS is committed to ensuring the availability of SE services throughout West Virginia as reflected in progress toward WVDRS Goal 5, which is to continue to build collaborative relationships with community providers including Community Rehabilitation Programs (CRPs), Independent Living, and other community providers to enhance the availability of services to WVDRS consumers. There are currently 64 WVDRS-acknowledged SE vendors from all districts across the state, a substantial increase from PY 2021. These vendors make SE services available to an increasing number of individuals with the most significant disabilities.  This trend is expected to continue with the increase in the number of providers, due in part to the increase in reimbursement rates for SE vendors.
In accordance with federal regulations, the SE services that may be provided to individuals and youth with disabilities placed in SE include:
1.	Evaluation of rehabilitation potential for SE to supplement the comprehensive assessment conducted under the Title I program;
2.	Job development;
3.	Job placement;
4.	Intensive on-the-job training provided by skilled job coaches/employment specialists;
5.	Case management services;
6.	Job monitoring, whether performed onsite or offsite, that includes regular contact with employees, employers, parents, guardians, and other professionals to reinforce and maintain the job placement;
7.	Rehabilitation technology assessment and services as appropriate; and
8.	Post-employment services (following transition to extended SE services) that are available from the extended service provider and that are needed to maintain the SE job placement.
The demand and need for SE services continues to be significant, particularly in rural areas, as well as for those individuals who are transitioning from school to the workforce. WVDRS continues its commitment to expanding the statewide capacity for SE services.
WVDRS will continue to provide SE services to its consumers and will acknowledge additional SE service providers where needed. The Division will continue to consider non-traditional approaches to SE service delivery and will increasingly emphasize the development of natural supports wherever possible. WVDRS anticipates that more individuals will receive services with the increased number of approved SE providers.
WVDRS authorized SE services to 272 individuals in Program Year 2022.
While SE services may be expected to vary in scope and duration from individual to individual, core services that may be provided to individuals and youth with disabilities placed in SE can include:
1.	Assessment of the individual’s environmental circumstances;
2.	Job analysis and job development;
3.	Rehabilitation technology assessment;
4.	Job placement following appropriate match of job/consumer characteristics identified during assessment, job analysis, and job development (services 1 and 2 above);
5.	Intensive, one-on-one, on-the-job training;
6.	Job stabilization, job coach fading as much as possible; and
7.	Extended Supported Employment Services (ESES), optimally including natural supports.
THE TIMING OF TRANSITION TO EXTENDED SERVICES
WVDRS receives state funds earmarked to provide ESES for SE clients closed as successfully rehabilitated who, after an assessment of their progress and continuing needs for services, are found to require ongoing job coaching to maintain employment and are not eligible for services through other funding sources. The consumer’s Individualized Plan for Employment (IPE) includes an estimate of the time needed for transition to extended services. Provision of ESES (job coaching) to all eligible SE clients, including youth with the most significant disabilities, in accordance with an approved IPE will not exceed four years, as required by federal regulations.
Consumers in SE placement are eligible to receive any services traditionally available through the WVDRS Title I program.
4. Sections 101(a)(22) and 606(b)(4) of the Rehabilitation Act require the VR agency to describe efforts to identify and arrange, including entering into cooperative agreements, with other State agencies and other appropriate entities in order to provide supported employment services. The description must include extended services, as applicable, to individuals with the most significant disabilities, including the provision of extended services to youth with the most significant disabilities in accordance with 34 C.F.R. § 363.4(a) and 34 C.F.R. § 361.5(c)(19)(v).
The West Virginia Division of Rehabilitation Services (WVDRS) continues to concentrate efforts on educating interested parties regarding the process of becoming a non-traditional provider source for supported employment services. A variety of supported employment provider choices are needed, particularly due to the rural nature of the state.
WVDRS continues to focus on providing technical assistance and coordinating training for vendors of supported employment services, WVDRS staff members, and staff members of other public and private agencies. WVDRS keeps current on changes and advances in supported employment through documented research, literature, and reviews of best practices.
Other agencies with which WVDRS collaborates for the provision of time-limited supported employment services are:
1.	West Virginia Developmental Disabilities Council funds;
2.	West Virginia Title XIX––Home and Community-Based Waiver Program for intellectual/developmental disabilities (I/DD) recipients; and
3.	Social Security Administration work incentives programs.
In implementing school-to-work transition services for individuals exiting the school system, WVDRS also collaborates with family resource networks.
Through a combined effort with other disability organizations, $78,000 was appropriated (annually since 2017) by the West Virginia Legislature for supported employment follow-along services (extended supported employment services). WVDRS serves as the fiscal agent for these funds. WVDRS has created program guidelines governing the use of state-appropriated funds for extended services under the supported employment program created by state statute in 1993. The sole use of the state funds attached to this program is to provide extended services for individuals not eligible from any other funding source. All providers of supported employment services may access these funds for individuals who are eligible under the guidelines. At the end of Program Year 2022, WVDRS had sponsored 24 individuals in the extended supported employment program so they could maintain and retain their jobs within the community. This figure represents the cooperative efforts of seven CRPs.
Agreements between WVDRS and all acknowledged providers of supported employment services document collaboration for extended services. Each agreement details the time-limited and extended services that WVDRS will secure through the vendor.
Extended services specified in the agreement will be provided by the vendor and include, at minimum, monitoring two hours per month (no more than eight) at the job site of each individual unless the individual can be better served through offsite monitoring. If offsite monitoring is determined to be appropriate, it must, at a minimum, consist of two hours per month with the individual and at least one contact with the employer during those hours. The vendor also agrees to provide other support services as needed and specified in the Individualized Plan for Employment.
In addition to the basic vendor agreement identifying the time-limited and extended services to be mutually provided by WVDRS and the vendor, WVDRS has attempted to collaborate with other agencies and organizations to provide funding for extended services.
These sources of extended supported employment services are:
1.	West Virginia Title XIX––Homes and Community-Based Waiver Program for I/DD recipients;
2.	WVDRS program funds for persons receiving extended services at WVDRS-acknowledged CRP work centers; and
3.	Social Security Administration programs such as Impairment Related Work Expenses and Plan to Achieve Self Support for approved Social Security recipients.
WVDRS continues its efforts to expand the number of acknowledged vendors of supported employment services, particularly in areas underserved and unserved within the current system. As of November 2023, the number of supported employment service providers was 64, an increase of 26 providers since Fiscal Year 2006.
f. Annual Estimates
Sections 101(a)(15) and 101(a)(23) of the Rehabilitation Act require all VR agencies to annually conduct a full assessment of their resources and ability to serve all eligible individuals before the start of the Federal fiscal year. In accordance with 34 C.F.R. § 361.29(b), annual estimates must include the following projections:
1. Estimates for next Federal fiscal year—
A. VR Program; and
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Priority Category (if applicable)	No. of Individuals Eligible for Services	No. of Eligible Individuals Expected to Receive Services under VR Program	Costs of Services using Title I Funds	No. of Eligible Individuals Not Receiving Services (if applicable)	
1	4,137	4,137	$10,045,208	n/a	
2	6,344	6,344	$17,756,589	n/a	
3	1,691	1,691	$2,811,311	n/a	

B. Supported Employment Program.
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Priority Category (if applicable)	No. of Individuals Eligible for Services	No. of Eligible Individuals Expected to Receive Services under Supported Employment Program	Costs of Services using Title I and Title VI Funds	No. of Eligible Individuals Not Receiving Services (if applicable)	
n/a	357	357	$447,338	n/a	
g. Order of Selection
1. Pursuant to Section 101(a)(5) of the Rehabilitation Act, this description must be amended when the VR agency determines, based on the annual estimates described in description (f), that VR services cannot be provided to all eligible individuals with disabilities in the State who apply for and are determined eligible for services.
*  VR agencies may maintain an order of selection policy and priority of eligible individuals without implementing or continuing to implement an order of selection.
                        The VR agency is not implementing an order of selection and all eligible individuals will be served.
2. For VR agencies that have defined priority categories describe—
A. The justification for the order
N/A
B. The order (priority categories) to be followed in selecting eligible individuals to be provided VR services ensuring that individuals with the most significant disabilities are selected for services before all other individuals with disabilities; and
N/A
C. The VR agency’s goals for serving individuals in each priority category, including how the agency will assist eligible individuals assigned to closed priority categories with information and referral, the method in which the VR agency will manage waiting lists, and the projected timelines for opening priority categories. NOTE: Priority categories are considered open when all individuals in the priority category may be served.
N/A
3. Has the VR agency elected to serve eligible individuals outside of the order of selection who require specific services or equipment to maintain employment?
N/A
h. Waiver of Statewideness.
The State plan shall be in effect in all political subdivisions of the State, however, the Commissioner of the Rehabilitation Services Administration (Commissioner) may waive compliance with this requirement in accordance with Section 101(a)(4) of the Rehabilitation Act and the implementing regulations in 34 C.F.R. § 361.26. If the VR agency is requesting a waiver of statewideness or has a previously approved waiver of statewideness, describe the types of services and the local entities providing such services under the waiver of statewideness and how the agency has complied with the requirements in 34 C.F.R. § 361.26. If the VR agency is not requesting or does not have an approved waiver of statewideness, please indicate “not applicable.”
The West Virginia Division of Rehabilitation Services has not requested a waiver of statewideness.
i. Comprehensive System of Personnel Development.
In accordance with the requirements in Section 101(a)(7) of the Rehabilitation Act, the VR agency must develop and maintain annually a description (consistent with the purposes of the Rehabilitation Act) of the VR agency’s comprehensive system of personnel development, which shall include a description of the procedures and activities the State VR agency will undertake to ensure it has an adequate supply of qualified State rehabilitation professionals and paraprofessionals that provides the following:
1. Analysis of current personnel and projected personnel needs including—
A. The number of personnel currently needed by the VR agency to provide VR services, broken down by personnel category; and
B. The number and type of personnel that are employed by the VR agency in the provision of vocational rehabilitation services, including ratios of qualified vocational rehabilitation counselors to clients;
C. Projections of the number of personnel, broken down by personnel category, who will be needed by the VR agency to provide VR services in 5 years based on projections of the number of individuals to be served, including individuals with significant disabilities, the number of personnel expected to retire or leave the field, and other relevant factors.
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WVDRS is committed to providing a comprehensive system of personnel development (CSPD) that complies with Section 101(a)(7)(A) of the Rehabilitation Act Amendments of 1998 and Section 721(a)(7)(A) of the Rehabilitation Act, as amended by the Workforce Innovation and Opportunity Act (WIOA) of 2014. Members of the State Rehabilitation Council are afforded the opportunity to review and comment upon this entire section, particularly the WVDRS plan for recruitment, preparation, and retention of qualified personnel, agency personnel standards, and staff development needs and activities.
Provisions of this section should assist in recruiting and retaining qualified staff members to ensure skilled personnel are available to provide rehabilitation services to individuals with disabilities. Furthermore, these endeavors will help ensure an improved level of competence and expand and improve vocational rehabilitation services for individuals with disabilities, especially those with the most significant disabilities, allowing them to reach employment.
The Human Resources Unit is primarily responsible for performing WVDRS personnel administration activities in keeping with guidance from the West Virginia Division of Personnel (WVDOP), Rehabilitation Services Administration, Social Security Administration, and other appropriate bodies. The Quality Assurance (QA) Unit also works closely with the Field Services Unit to ensure quality and timely training for new field counselors and rehabilitation services associates (RSAs).
The following narrative describes the WVDRS CSPD and policies, procedures, and activities relating to the establishment and maintenance of standards to ensure that personnel needed within WVDRS are appropriately and adequately prepared and trained for WVDRS operations.
WVDRS Data System on Personnel and Personnel Development Needs
Statistics and information utilized for personnel planning are maintained within the Human Resources Unit. WVDRS administrators can review salary, pay grade, job title, reporting unit, and personal employee information. Such information is available to WVDRS Assistant Directors and District Managers who use it for planning, hiring negotiations, and pay equity. WVDRS retiree information may also be obtained from these databases.
The Human Resources Senior Manager periodically (at least monthly) maintains and provides statistical data to the WVDRS Director. The data includes a list of the number of individuals under various classifications who are employed by WVDRS in the provision of rehabilitation services, as well as a ratio of the number of counselors to the number of consumers served each year. WVDRS estimates the ratio of consumers served (12,172) to the number of counselors (78) will be 156 in Program Year (PY) 2024.
Each year, the WVDRS Director receives a summary report that estimates and projects the number of such personnel that will be needed during the next five–year period. In November 2023, WVDRS had 78 counselors in various offices across the state. Of the 78 counselors, WVDRS had 24 Rehabilitation Counselors, 21 Senior Rehabilitation Counselors, 12 Certified Rehabilitation Counselors, and 21 Rehabilitation Counselor Trainees. WVDRS believes its existing counselors and field staff members are needed to provide services to consumers who are currently in the WVDRS system.
WVDRS had several unfilled positions as of November 2023: 5 Rehabilitation Counseling positions, 3 Senior Rehabilitation Counselor positions, 3 Certified Rehabilitation Counselor positions, and 2 Rehabilitation Counselor Trainee positions. Each unfilled position is being used to expand the number of field counselors, when needed.
A breakdown by personnel category, including the number of personnel in relation to the estimated number of individuals served in PY 2024, is as follows (information current as of November 2023):
•	Rehabilitation Counselors: 29 total positions (including 5 vacancies), and 12 projected vacancies over the next five years. The ratio of individuals to be served to the number of Rehabilitation Counselors is 420.
•	Senior Rehabilitation Counselors: 24 total positions (including 3 vacancies), and 7 projected vacancies over the next five years. The ratio of individuals to be served to the number of Senior Rehabilitation Counselors 507.
•	Certified Rehabilitation Counselors: 15 total positions (including 3 vacancies), and 5 projected vacancies over the next five years. The ratio of individuals to be served to the number of Certified Rehabilitation Counselors is 811.
•	Rehabilitation Counselor Trainee: 23 total positions (including 2 vacancies), and 9 projected vacancies over the next five years. The ratio of individuals to be served to the number of Rehabilitation Counselor Trainees is 529.
•	Fiscal personnel: 9 total positions (including 2 vacancies), and 1 projected vacancy over the next five years. The ratio of individuals to be served to the number of Fiscal personnel is 1,352.
•	Administrative Services personnel: 9 total positions (including 1 vacancy), and 6 projected vacancies over the next five years. The ratio of individuals to be served to the number of Administrative Services personnel is 1,352.
•	Field Services personnel: 185 total positions (including 25 vacancies), and 65 projected vacancies over the next five years. The ratio of individuals to be served to the number of Field Services personnel is 66.
•	Support Services personnel (e.g., human resources, rehabilitation technology unit): 42 total positions (including 3 vacancies), and 17 projected vacancies over the next five years. The ratio of individuals to be served to the number of Support Services personnel is 290.
•	Information Technology personnel: 8 total positions (including 0 vacancies), and 4 projected vacancies over the next five years. The ratio of individuals to be served to the number of Information Technology personnel is 1,522.
•	Other personnel (e.g., vocational instructors, technical analysts): 21 total positions (including 3 vacancies), and 10 projected vacancies over the next five years. The ratio of individuals to be served to the number of other personnel is 580.
WVDRS expects to see an increase in the number of consumers in its caseload system, from 10,652 individuals in PY 2022 to a projected 14,275 individuals in PY 2028. WVDRS administrators believe that the expected future caseload size will be managed by existing counseling personnel and the gradual filling of the 13 vacant counselor positions over the next five years. Additionally, WVDRS employs 55 RSAs to assist Counselors with their caseloads in order to more efficiently meet the needs of the increasing number of consumers.
The following information presents a range of the number of counselors and other agency personnel projected to leave WVDRS employment after becoming eligible for early retirement under the West Virginia Public Employees Retirement System by PY 2028. Of the 23 counselors who will be eligible, there will be 6 Rehabilitation Counselors, 7 Senior Rehabilitation Counselor, and 10 Certified Rehabilitation Counselors; no Rehabilitation Counselor Trainees are projected to retire by PY 2028. WVDRS continues to experience a gradual retirement of counselors and other personnel. The agency expects this trend will continue over the coming years.
 
Personnel Category	No. of Personnel Employed	No. of Personnel Currently Needed	Projected No. of Personnel Needed in 5 Years	
Counselor (includes four distinct counselor position categories, see narrative for detailed breakdown)	78	91	99	
Administrative (includes fiscal and IT personnel, see narrative for detailed breakdown)	23	26	26	
Support Services	39	42	42	
Field Services	160	185	190	
Other	18	21	21	
 	 	 	 	
D. Ratio of qualified VR counselors to clients:
Statistics and information utilized for personnel planning are maintained within the Human Resources Unit. WVDRS administrators can review salary, pay grade, job title, reporting unit, and personal employee information. Such information is available to WVDRS Assistant Directors and District Managers who use it for planning, hiring negotiations, and pay equity. WVDRS retiree information may also be obtained from these databases.
The Human Resources Senior Manager periodically (at least monthly) maintains and provides statistical data to the WVDRS Director. The data includes a list of the number of individuals under various classifications who are employed by WVDRS in the provision of rehabilitation services, as well as a ratio of the number of counselors to the number of consumers served each year. WVDRS estimates the ratio of consumers served (12,172) to the number of counselors (78) will be 156 in Program Year (PY) 2024.
Each year, the WVDRS Director receives a summary report that estimates and projects the number of such personnel that will be needed during the next five–year period. In November 2023, WVDRS had 78 counselors in various offices across the state. Of the 78 counselors, WVDRS had 24 Rehabilitation Counselors, 21 Senior Rehabilitation Counselors, 12 Certified Rehabilitation Counselors, and 21 Rehabilitation Counselor Trainees. WVDRS believes its existing counselors and field staff members are needed to provide services to consumers who are currently in the WVDRS system.
WVDRS had several unfilled positions as of November 2023: 5 Rehabilitation Counseling positions, 3 Senior Rehabilitation Counselor positions, 3 Certified Rehabilitation Counselor positions, and 2 Rehabilitation Counselor Trainee positions. Each unfilled position is being used to expand the number of field counselors when needed.
A breakdown by personnel category, including the number of personnel in relation to the estimated number of individuals served in PY 2024, is as follows (information current as of November 2023):
•	Rehabilitation Counselors: 29 total positions (including 5 vacancies), and 12 projected vacancies over the next five years. The ratio of individuals to be served to the number of Rehabilitation Counselors is 420.
•	Senior Rehabilitation Counselors: 24 total positions (including 3 vacancies), and 7 projected vacancies over the next five years. The ratio of individuals to be served to the number of Senior Rehabilitation Counselors 507.
•	Certified Rehabilitation Counselors: 15 total positions (including 3 vacancies), and 5 projected vacancies over the next five years. The ratio of individuals to be served to the number of Certified Rehabilitation Counselors is 811.
•	Rehabilitation Counselor Trainee: 23 total positions (including 2 vacancies), and 9 projected vacancies over the next five years. The ratio of individuals to be served to the number of Rehabilitation Counselor Trainees is 529.
•	Fiscal personnel: 9 total positions (including 2 vacancies), and 1 projected vacancy over the next five years. The ratio of individuals to be served to the number of Fiscal personnel is 1,352.
•	Administrative Services personnel: 9 total positions (including 1 vacancy), and 6 projected vacancies over the next five years. The ratio of individuals to be served to the number of Administrative Services personnel is 1,352.
•	Field Services personnel: 185 total positions (including 25 vacancies), and 65 projected vacancies over the next five years. The ratio of individuals to be served to the number of Field Services personnel is 66.
•	Support Services personnel (e.g., human resources, rehabilitation technology unit): 42 total positions (including 3 vacancies), and 17 projected vacancies over the next five years. The ratio of individuals to be served to the number of Support Services personnel is 290.
•	Information Technology personnel: 8 total positions (including 0 vacancies), and 4 projected vacancies over the next five years. The ratio of individuals to be served to the number of Information Technology personnel is 1,522.
•	Other personnel (e.g., vocational instructors, technical analysts): 21 total positions (including 3 vacancies), and 10 projected vacancies over the next five years. The ratio of individuals to be served to the number of other personnel is 580.
E. Projected number of individuals to be served in 5 years:
WVDRS expects to see an increase in the number of consumers in its caseload system, from 10,652 individuals in PY 2022 to a projected 14,275 individuals in PY 2028. WVDRS administrators believe that the expected future caseload size will be managed by existing counseling personnel and the gradual filling of the 13 vacant counselor positions over the next five years. Additionally, WVDRS employs 55 RSAs to assist Counselors with their caseloads to more efficiently meet the needs of the increasing numbers of consumers.
The following information presents a range of the number of counselors and other agency personnel projected to leave WVDRS employment after becoming eligible for early retirement under the West Virginia Public Employees Retirement System by PY 2028. Of the 23 counselors who will be eligible, there will be 6 Rehabilitation Counselors, 7 Senior Rehabilitation Counselor, and 10 Certified Rehabilitation Counselors; no Rehabilitation Counselor Trainees are projected to retire by PY 2028. WVDRS continues to experience a gradual retirement of counselors and other personnel. The agency expects this trend will continue over the coming years.
2. Data and information on personnel preparation and development, recruitment and retention, and staff development, including the following:
A. A list of the institutions of higher education in the State that are preparing VR professionals, by type of program; the number of students enrolled at each of those institutions, broken down by type of program; and the number of students who graduated during the prior year from each of those institutions with certification or licensure, or with the credentials for certification or licensure, broken down by the personnel category for which they have received, or have the credentials to receive, certification or licensure.
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WVDRS annually collects information from higher education institutions that provide training to prospective rehabilitation personnel. Based on information provided by West Virginia University (WVU) and Marshall University, WVU reports 57 students enrolled in the Clinical Rehabilitation and Mental Health Counseling graduate programs in the Fall 2023 semester and 27 graduates in the 2022-2023 academic year. For the Counseling graduate program, WVU reports 51 enrolled students for Fall 2023 and 26 graduates during the 2022-2023 academic year. For the Social Work graduate program, WVU has an approximate enrollment of 58 students in Fall 2023 and 35 graduates in the 2022-2023 period.
Institute of Higher Education	Type of Program	No. of Students Enrolled	No. of Prior Year Graduates	
West Virginia University	Clinical Rehabilitation and Mental Health Counseling	57	27	
West Virginia University	Counseling	51	26	
West Virginia University	Social Work	58	35	
 	 	 	 	
B. The VR agency’s plan for recruitment, preparation and retention of qualified personnel, which addresses the current and projected needs for qualified personnel; and the coordination and facilitation of efforts between the VR agency and institutions of higher education and professional associations to recruit, prepare, and retain personnel who are qualified, including personnel from minority backgrounds and personnel who are individuals with disabilities.
WVDRS Recruitment Efforts
WVDRS will continue its efforts to recruit and advance employees of traditionally underrepresented groups such as people with disabilities, seniors, women, and members of racial or ethnic minority groups.
In PY 2023, WVDRS continued efforts to recruit with several postsecondary institutions in West Virginia. Through a partnership with West Virginia University, WVDRS is providing internship opportunities for graduate students in several programs of study, including Clinical Rehabilitation and Mental Health Counseling. WVDRS is also working with West Virginia State University, one of the state’s historically black colleges and universities, to provide internship opportunities for its students. WVDRS allows up to three interns per district for a total of 18 interns possible each semester (Spring, Summer, and Fall). Interns must express interest in vocational rehabilitation and be in a bachelor’s- or master’s-level program with a vocational rehabilitation-related degree to be considered. WVDRS works with each university to comply with their program requirements to the extent possible, while providing real-world training similar to what the Rehabilitation Counselor Trainee receives.
In addition to offering internships, WVDRS posts all permanent positions available to the public on Handshake (https://joinhandshake.com/employers/). Handshake is connected to each postsecondary institution in West Virginia and allows WVDRS job postings to be seen by current students and graduates.
WVDRS Re-training Efforts for Existing Rehabilitation Professionals
WVDRS is in full compliance with the CSPD requirement and its standard to employ only rehabilitation counselors who (1) possess a master’s degree in rehabilitation counseling or a counseling-related field, or (2) are employees who have two years of full-time or equivalent part-time paid experience in the position of Rehabilitation Counselor Trainee. As stated above, WVDRS makes no exceptions to the state standard when hiring new rehabilitation counselors.  Therefore, WVDRS provides for existing personnel to receive the training necessary to meet requirements of the state standard.
As part of its non-discriminatory employment practices, WVDRS ensures that all personnel are selected for employment without regard to race, color, religion, sex (including pregnancy, sexual orientation, or gender identity), national origin, age (40 or older), disability, and genetic information (including family medical history). The WVDRS affirmative action plan is updated annually, and the agency has formally adopted this policy of non-discriminatory employment practices.
C. Description of staff development policies, procedures, and activities that ensure all personnel employed by the VR agency receive appropriate and adequate training and continuing education for professionals and paraprofessionals:
i. Particularly with respect to assessment, vocational counseling, job placement, and rehabilitation technology, including training implemented in coordination with entities carrying out State programs under section 4 of the Assistive Technology Act of 1998; and
ii. Procedures for the acquisition and dissemination of significant knowledge from research and other sources to VR agency professionals and paraprofessionals and for providing training regarding the amendments to the Rehabilitation Act made by the Workforce Innovation and Opportunity Act.
Staff Development and Training Activities
The selection of WVDRS participants for training activities is based upon documented organizational, unit, or individual training needs. Training programs will be provided for all classes and types of staff members on an internally assessed priority basis. Particular emphasis is placed on programs addressing assessment, vocational counseling, job placement, policy and procedure, ethics, and rehabilitation technology. WVDRS does not discriminate in the selection of trainees for these programs based on age, sex, religion, disability, and national or ethnic origin.
WVDRS is committed to utilizing only institutions or training facilities that are accessible programmatically and architecturally free of other barriers with respect to trainees with disabilities. In addition, WVDRS will ensure that program materials are accessible in the most appropriate format for all participants with disabilities (assistive communication devices, interpreters, large print, audio tapes, Braille material, etc.). The technology to ensure these accommodations is available through various support units within WVDRS. Moreover, to promote equal access for individuals with disabilities in facilities of higher education, WVDRS houses a rehabilitation counselor on campus at Marshall University and West Virginia University.
Typically, the majority of the training needs are met through local training and the agency’s annual State Training Conference. WVDRS staff also participate in other training opportunities, when appropriate, through institutions of higher education, particularly those receiving funds from the Rehabilitation Services Administration to train rehabilitation professionals. This is to ensure that personnel needed within WVDRS are appropriately and adequately prepared for employment. In 2022, 20 WVDRS staff participated in Pre-ETS training provided by West Virginia University Research Corporation through an RSA Innovative Training program grant.
Throughout PYs 2022 and 2023, WVDRS continued to utilize a group training approach for newly hired counselors and RSAs; 20 new counselors and counselor trainees and 34 RSAs were trained during PY 2022, and 25 new counselors and counselor trainees and 17 RSAs were trained during PY 2023 through October 2023. The training is led by QA Unit staff members and consists of multiple sessions, provided on an as-needed basis for new hires (minimum of 2 new hires per cohort). The training begins with introductory materials, as well as training on case management and agency policies and procedures. Later sessions cover Decision Tree Training, detailing appropriate casework practices from referral to closure. In addition to the training, as part of their NCT/RSA module training, new hires receive a CRP services overview and information about the agency’s Rehabilitation Services Programs Unit and a tour of their work area(s), including the Rehabilitation Technology Unit. This approach ensures that all rehabilitation counselors and paraprofessionals receive standardized and accurate training.
QA Unit staff members and branch office managers conduct regular case record reviews to ensure compliance with federal, state, and agency casework standards. Any deficiencies identified from the reviews are addressed through appropriate training.
All WVDRS-sponsored programs provide continuing education credits that assist WVDRS CRCs, Licensed Professional Counselors, and members of other certified groups to maintain or obtain their certification. WVDRS has received approval authority from the CRCC to provide CRC continuing education credits for training programs meeting CRCC criteria.
WVDRS managers and supervisors also attend management training events to meet the requirements for the West Virginia Division of Personnel Policy 18, which mandates specialized training for all supervisors and managers. New managers and supervisors are required to take eight classes in their first two years.  During PY 2022, 45 managers or supervisors participated in 154 DOP-18 training courses. 
In June 2022, WVDRS held a WIOA Partners Conference in Morgantown, WV. Thirty-three partner agencies were represented, including representation from WV Combined State Plan agencies, with a total of 216 participants. This conference was followed by the WVDRS State Conference, also held in Morgantown, WV, with 220 participants. In June 2023, WVDRS held a Statewide Conference in Morgantown, WV, with 200 staff members in attendance and with 16 exhibitors from around the state. In September 2023, WVDRS held a Clerical Conference at its Administrative Office in Nitro, WV; 52 staff members attended this conference.  These conferences help ensure that all staff members are connected to the overall mission and vision of the agency.
WVDRS staff confront the challenge of refining and improving their skills and knowledge while dealing with the current explosion of knowledge, technology, and treatment modalities. WVDRS will continue to make intensive efforts to provide ongoing information that will ensure the skills of WVDRS employees are responsive to the needs of the people they serve.
With respect to training implemented in coordination with entities carrying out State programs under section 4 of the Assistive Technology Act of 1998, WVDRS maintains a working relationship and a formal memorandum of understanding with the West Virginia Assistive Technology System (WVATS). In West Virginia, the WVATS, under the Center for Excellence in Disabilities at West Virginia University, is the administrator of the assistive technology grant. WVDRS is also represented on the West Virginia Assistive Technology Board and works with WVATS in a number of ways, including:
•	Maintain an updated resource database for Assistive Technology services in West Virginia.
•	Participate in special projects (i.e., finding and advocating for accessible recreational resources).
•	Provide information resources, awareness, and training for consumers and professionals in assistive technology services and devices.
•	Provide information to WVATS partners regarding WVDRS and other disability-related subjects; and
•	Participate as a member on an interagency team, Partnerships in Assistive Technologies, with a focus of interagency collaboration for the provision of Assistive Technology training and conferences.
3. Description of VR agency policies and procedures for the establishment and maintenance of personnel standards consistent with section 101(a)(7)(B) to ensure that VR agency professional and paraprofessional personnel are adequately trained and prepared, including—
A. Standards that are consistent with any national or State-approved or -recognized certification, licensing, registration, or other comparable requirements that apply to the profession or discipline in which such personnel are providing VR services; and
B. The establishment and maintenance of education and experience requirements, in accordance with section 101(a)(7)(B)(ii) of the Rehabilitation Act, to ensure that the personnel have a 21st century understanding of the evolving labor force and the needs of individuals with disabilities.
To ensure a high standard of competency and credentials for its qualified rehabilitation professionals, WVDRS has established job classifications. The lowest standard for Rehabilitation Counselors requires a master’s degree in rehabilitation counseling, counseling and guidance, social work, or closely related behavioral science field; or two years of experience as a Rehabilitation Counselor Trainee. Senior Rehabilitation Counselors require: (1) a master’s degree in rehabilitation counseling or counseling-related field; and (2) two years of full-time or equivalent part-time paid professional experience in vocational rehabilitation counseling.
Certified Rehabilitation Counselors require: (1) a master’s degree in rehabilitation counseling or counseling-related field; (2) current national certification as a Certified Rehabilitation Counselor or Certified Vocational Evaluator or current West Virginia licensure as a Licensed Professional Counselor; and (3) at least three years of full-time or equivalent part-time paid professional experience as a rehabilitation counselor.
WVDRS has established the position of Rehabilitation Counselor Trainee. An employee in this position is under direct supervision and performs work at the entry level in a probationary training capacity, which is intended to qualify the employee for specific duties for this position. The employee may become eligible for the position of Rehabilitation Counselor after two years of full-time or equivalent part-time paid experience in the position of Rehabilitation Counselor Trainee. The minimum qualifications for the Rehabilitation Counselor Trainee position are a bachelor’s degree from a regionally accredited college or university.
WVDRS strives to recruit graduates of accredited master’s degree programs in rehabilitation like the one at WVU, but it does not require the Certified Rehabilitation Counselor (CRC) credential as the minimum qualification for a new counselor. Graduates of accredited master’s degree programs in rehabilitation counseling are eligible for certification by the Commission on Rehabilitation Counselor Certification (CRCC), which sets the national standards for quality rehabilitation counseling services in the U.S. WVDRS encourages the achievement of CRC by existing counselors and gives special preference to applicants with the CRC credential and qualified applicants with disabilities and from minority backgrounds.  The WVDRS standard is specific to rehabilitation counselors only and is consistent with registration requirements of WVDOP, the WV state hiring authority. WVDOP administers and scores unassembled examinations to potential rehabilitation counselor candidates.
To ensure that counselors and other personnel remain up to date with evolving labor force needs and the needs of individuals with disabilities, WVDRS provides ongoing training opportunities for its field staff in group and individual settings. This occurs through educational activities such as the State training conference, periodic district-level training sessions, continuing education credit opportunities (Certified Rehabilitation Counselor), and training sessions by WVDRS Quality Assurance Specialists and WVDRS Employment Specialists. These activities allow WVDRS counselors and field staff to enhance their knowledge of labor force needs and ultimately better serve individuals with disabilities.
Individuals not meeting the above personnel standards for rehabilitation professionals are ineligible to interview for vacant rehabilitation counseling positions. Classification specifications for each position utilized by WVDRS are available through the WVDOP website: https://www.governmentjobs.com/careers/wv/classspecs.
When employing new rehabilitation counselors, WVDRS makes no exceptions to its standard and provides the training necessary to meet requirements of the state standard only to existing personnel. These efforts are described later in this section.
Should qualified candidates be unavailable, the WVDRS Director, Assistant Directors, Human Resources Manager, and the Unit Manager or District Manager may reassess staffing/consumer needs and reassign qualified employees to assume duties of the vacant position. Qualified WVDRS retirees may also be rehired on a contractual/intermittent basis until permanent qualified employees can be hired.
The career ladder for advancement within the rehabilitation counseling ranks requires additional experience and credentials as well as increased responsibilities.
WVDRS Requirements for Qualified Rehabilitation Paraprofessionals
In order to more efficiently meet the needs of its consumers, WVDRS upgraded several clerical positions to paraprofessional status. A Rehabilitation Services Associate must be a high school (or equivalent) graduate and have at least four years of full-time or equivalent part-time paid experience in paraprofessional or responsible clerical office support work, which requires familiarity with casework procedures and delivery of direct consumer services in a state vocational rehabilitation services agency. A bachelor’s degree from an accredited four-year college or university may be substituted for the required experience. The WVDOP specification for the Rehabilitation Services Associate position may be accessed at https://www.governmentjobs.com/careers/wv/classspecs.
A Rehabilitation Services Associate assists qualified rehabilitation counselors in several ways: providing information about the rehabilitation process and services available to interested applicants and members of the general public; obtaining information needed to complete the application process; initiating vocational diagnostic interviews; arranging medical, psychological, and vocational evaluations for WVDRS consumers; and assisting consumers in applying for student financial aid.
WVDRS employed 55 Rehabilitation Services Associates as of November 2023. These paraprofessionals are assigned to WVDRS offices throughout West Virginia. To ensure statewide coverage, at least one is located within each WVDRS district.
System of Staff Evaluation
WVDRS requires that each permanent employee receive an annual job performance evaluation. The work performance of probationary employees is reviewed upon completion of the third and sixth (and for certain job classifications, twelfth) months during a probationary period. This evaluation system enables WVDRS to monitor the job performance of all staff members and identify areas of weakness and skill deficiencies that need training or remediation, as well as areas of strong performance. The evaluation also provides a systematic method of determining training needs for all staff members.
4. Method(s) the VR agency uses to ensure that personnel are able to communicate in appropriate modes of communication with or in the native language of applicants or eligible individuals who have limited English speaking ability.
West Virginia does not have large populations of ethnic groups who speak a language other than English. Consequently, WVDRS has not experienced difficulties making its programs accessible and available statewide. In rare instances where non-English language interpreters are needed, WVDRS has obtained those services from interpreters at the local level.  An additional resource for non-English language interpreters is through the Job Accommodation Network (JAN) housed at West Virginia University.  If needed, there are interpreters registered with the State of West Virginia who also offer interpreting services for languages other than English.  In 2023, WVDRS added multiple options for virtual language and American Sign Language (ASL) interpreting services available anytime on demand.
The agency’s main language accessibility needs concern people who are deaf, and each WVDRS district is staffed with a specialist counselor providing full access to programs and services for people who have deafness or hearing impairments.  If needed, virtual interpreting services are available anytime on demand.
WVDRS continues to work with the West Virginia Commission for the Deaf and Hard of Hearing to train and certify interpreters to strengthen the network of providers for people who are deaf, hard of hearing, or deaf-blind. Numerous workshops and seminars are conducted to increase the number of interpreters, improve their communication skills, and provide better statewide coverage. These coordinated efforts will continue as needed.
WVDRS also ensures that its employees and consumers with blindness or visual impairments receive information and materials in their preferred mode of communication through various accommodations. Upon request, various WVDRS support units provide such services as assistive communication devices, large print and/or Braille materials, audiotapes, and electronic (computer) copies.
5. As appropriate, describe the procedures and activities to coordinate the designated State unit's comprehensive system of personnel development with personnel development under the Individuals with Disabilities Education Act.
WVDRS will continue to coordinate its system of personnel development with the West Virginia Department of Education’s (WVDE) personnel development under the Individuals with Disabilities Education Act/No Child Left Behind Act of 2001. This coordination will include collaborative efforts to share information, liaison activities, and cooperative training endeavors for WVDRS school counselors, teachers, and WVDE employees, particularly those assigned to the Office of Special Education.
The WVDRS state level liaison attends WVDE training functions related to special education and disseminates information about education policy or law changes to WVDRS school counselors as needed. WVDRS school counselors also receive information during their annual meeting. WVDRS school counselors also participate in cross-training efforts. In some areas of the state, WVDRS school counselors and managers participate in local interagency planning groups where training issues are discussed and planned.
j. Coordination with Education Officials.
In accordance with the requirements in Section 101(a)(11)(D) of the Rehabilitation Act—
1. Describe plans, policies, and procedures for coordination between the designated State agency and education officials responsible for the public education of students with disabilities, that are designed to facilitate the transition of the students with disabilities from the receipt of educational services in school to the receipt of vocational rehabilitation services, including pre-employment transition services.
The West Virginia Division of Rehabilitation Services (WVDRS) has cooperative agreements with the West Virginia Department of Education (WVDE) Office of Special Education, the WVDE Division of Technical and Adult Education, Office of Adult Education and Workforce Development, local education agencies (county boards of education), and the West Virginia Schools for the Deaf and the Blind. The current cooperative agreement between WVDRS and WVDE (the state education agency) went into effect on November 27, 2023. The cooperative agreements between WVDRS and WVDE, both at the state and the local levels, assure that each student with a disability in the state who needs special education, vocational education, and/or vocational rehabilitation services is identified and that the appropriate services, including pre-employment transition services (Pre-ETS), are made available to the individual. The cooperative agreements cover:
•	Determination of agency responsibility;
•	Transition and Pre-ETS planning;
•	Outreach and identification;
•	Financial responsibility of education;
•	Financial responsibility of rehabilitation;
•	Consultation and technical assistance;
•	Confidentiality of information/sharing of information;
•	The duration of the agreement;
•	Local agreements;
•	Dispute resolution;
•	Modification of the agreement; and
•	Subminimum wage employment.
The following excerpt from the current formal agreement between WVDRS and WVDE outlines the coordination and documentation requirements, including the provision of Pre-ETS and transition services, for students seeking subminimum wage employment:
SUBMINIMUM WAGE EMPLOYMENT
Section 511 of the WIOA imposes requirements on WVDE and Rehabilitation with regard to youth with disabilities seeking subminimum wage employment. Rehabilitation and WVDE shall work cooperatively to ensure that the individual, before beginning work that is compensated at a subminimum wage, has completed, and produces documentation indicating completion of, each of the following actions:
1.	The individual has received pre-employment transition services that are available to the individual under section 113, or transition services under the Individuals with Disabilities Education Act (20 U.S.C. 1400 et seq.) such as transition services available to the individual under section 614(d) of that Act (20 U.S.C. 1414(d)).
2.	The individual has applied for vocational rehabilitation services under Title I, with the result that:
•	the individual has been found ineligible for such services pursuant to that title and has documentation consistent with section 102(a)(5)(C) regarding the determination of ineligibility; or
•	the individual has been determined to be eligible for vocational rehabilitation services;
•	the individual has an individualized plan for employment under section 102;
•	the individual has been working toward an employment outcome specified in such individualized plan for employment, with appropriate supports and services, including supported employment services, for a reasonable period of time without success; and
•	the individual's vocational rehabilitation case is closed; and
•	the individual has been provided career counseling and information and referrals to Federal and State programs and other resources in the individual 's geographic area that offer employment-related services and supports designed to enable the individual to explore, discover, experience, and attain competitive integrated employment; and
•	such counseling and information and referrals are not for employment compensated at a subminimum wage provided by an entity described in this subsection, and such employment-related services are not compensated at a subminimum wage and do not directly result in employment compensated at a subminimum wage provided by an entity described in this subsection.
Any student considering subminimum wage employment upon exiting high school should be referred to Rehabilitation. When appropriate, Rehabilitation may request documentation from WVDE for purposes related to this section. Rehabilitation will collect and document the necessary prerequisites, corresponding services, and information (described above) required of individuals (aged 24 and younger) seeking subminimum wage employment. This documentation will be provided to the individual within 45 days after the completion of services, or 90 days if a longer period of time is needed due to extenuating circumstances.
Furthermore, this agreement assures, pursuant to 34 CFR 397.31, that Rehabilitation and WVDE agree not to enter into a contract or other arrangement with an entity for purposes of operating a program in which youth with disabilities are employed at subminimum wage.”
WVDRS has a long history of working closely with the state and local education agencies. Since the implementation of the Workforce Innovation and Opportunity Act (WIOA), WVDRS has further strengthened these working relationships.  WVDRS has worked with the WVDE Office of Special Education to align WVDE policy with aspects of WIOA, particularly the provision of Pre-ETS. Education and WVDRS have jointly developed materials that are distributed to special education students and teachers across the state.
WVDRS’ Pathways to the Future materials are made available to students with disabilities, teachers, parents, and other stakeholders across the state. The materials include:
•	The PathwaysWV.org website
•	Pre-ETS transition slide guide
•	Parent/student guide
•	Transition Services Planner
•	Sample Lessons for Life After High School
As part of its ongoing outreach activities, WVDRS developed new Pathways to the Future banners and posters during FY 2022. These were distributed to all high schools in the state to ensure that students, parents, and teachers are aware of the availability of Pre-ETS. Additional outreach using large posters target eighth grade, career and technical education, and postsecondary students at locations across the state to ensure that students ages 14-21 are aware of the availability of Pre-ETS. The banners are also used by WVDRS during job fairs, transition fairs, and other activities involving students with disabilities.
As part of the Comprehensive Statewide Needs Assessment (CSNA), WVDRS attempted a one-on-one Pre-ETS needs assessment discussion with teachers and administrators in all of West Virginia’s 55 counties.  WVDRS received participation from 64 high schools in 29 (out of 55) counties in 2023.  All six WVDRS districts were represented. WVDRS continues to ensure that Pre-ETS are available to students with disabilities on a statewide basis.  Details and results of this assessment are provided in the Statewide Assessment section of the state plan.
To better serve students, WVDRS has offices located in some of the state’s largest schools, as well as the WV Schools for the Deaf and the Blind. Additionally, counselors visit every high school in the state to initiate rehabilitation services needed for transition from school to work. This allows the counselor to develop a collaborative relationship and assist the student in identifying goals, services, and service providers related to employment options prior to transition. In FY 2023, there were 82 rehabilitation counselors assigned to work with the state’s 55 local education agencies and the West Virginia Schools for the Deaf and Blind.
School rehabilitation counselors also are invited to participate in Individualized Education Program (IEP) meetings. During these meetings the counselor describes WVDRS services, policies, and procedures as appropriate. The WVDRS counselor determines the student’s eligibility and order of selection category utilizing information generated from the school, the student, and WVDRS. Prior to or shortly after the student’s IEP transition meeting occurs, development begins on the student’s Individual Plan for Employment (IPE) so both the student and counselor have an idea of what rehabilitation services will be necessary to meet the student’s vocational goal. Therefore, if the student needs additional training or assessment prior to vocational goal determination, this information is already collected so that planned rehabilitation services may begin. IPE development and approval for students with disabilities, including those able to be served if WVDRS is on an order of selection, will begin as early as appropriate during the transition process, but before the student, determined to be eligible, leaves the school setting.
WVDRS continues to work with WVDE on WV Guideposts to Graduation (WVGtG; formerly known as Graduation 20/20), a West Virginia initiative that uses a data driven intervention framework developed by the National Dropout Prevention Center for Students with Disabilities (NDPC–SD) to address issues that have negatively impacted school completion. WVGtG utilizes the innovation configuration on evidence-based transition practices and predictors of post-school success to guide professional learning, which was published by the Collaboration for Effective Educator, Development, Accountability, and Reform (CEEDAR) Center. The program, using tools from NDPC–SD and CEEDAR, trains local school-based teams and team leaders to diagnose the causes of dropout and to develop site-specific improvement plans and strategies.
Information about the WVDRS school program is widely disseminated to education professionals, as well as students and their parents. An updated fact sheet and new brochure explaining WVDRS transition services are available. WVDRS has negotiated an agreement with the West Virginia Higher Education Policy Commission for its consumers who attend in-state public colleges and universities. The agreement describes the financial responsibility of WVDRS and the appropriate public institution of higher education, provides procedures to resolve interagency disputes, and coordinates policies and procedures to ensure timely delivery of vocational rehabilitation services. To better serve individuals in postsecondary school, WVDRS has liaisons assigned to 43 postsecondary community/technical colleges, 4-year colleges, and universities across the state.
WVDRS also coordinates with the WVDE Office of Adult Education and Workforce Development, a WIOA core partner, to better serve individuals receiving adult education. The agencies have a formal Memorandum of Understanding (MOU) and collaborate at the state and local level. The MOU includes screening students for potential disabilities, including learning disabilities, and the collaboration between WVDE and WVDRS to provide necessary accommodations (e.g., assistive technology, interpreters) for eligible individuals. WVDRS will evaluate the disability or disabilities and provide specific recommendations regarding testing accommodations, recommendations for instructional accommodations, and recommendations for job accommodations. If it is found that the student requires assistive technology (which includes information technology products such as software applications, operating systems, web-based information applications, web accessibility, video equipment, multimedia products, and office equipment) then WVDE and WVDRS will share, as appropriate, the cost for this technology. If it is determined that the person has a hearing disability and it is deemed necessary that an interpreter, CART (Communication Access Realtime Translation), notetaker, or other appropriate accommodations be provided, then WVDE and WVDRS will share the cost. WVDE will only hire qualified interpreters who are registered through the West Virginia Commission for the Deaf and Hard of Hearing.
2. Describe the current status and scope of the formal interagency agreement between the VR agency and the State educational agency. Consistent with the requirements of the formal interagency agreement pursuant to 34 C.F.R. § 361.22(b), provide, at a minimum, the following information about the agreement:
A. Consultation and technical assistance, which may be provided using alternative means for meeting participation (such as video conferences and conference calls), to assist educational agencies in planning for the transition of students with disabilities from school to post-school activities, including pre-employment transition services and other vocational rehabilitation services;
B. Transition planning by personnel of the designated State agency and educational agency personnel for students with disabilities that facilitates the development and implementation of their individualized education programs (IEPs) under Section 614(d) of the Individuals with Disabilities Education Act;
C. The roles and responsibilities, including financial responsibilities, of each agency, including provisions for determining State lead agencies and qualified personnel responsible for transition services and pre-employment transition services;
D. Procedures for outreach to and identification of students with disabilities who need transition services and pre-employment transition services. Outreach to these students should occur as early as possible during the transition planning process and must include, at a minimum, a description of the purpose of the vocational rehabilitation program, eligibility requirements, application procedures, and scope of services that may be provided to eligible individuals;
E. Coordination necessary to satisfy documentation requirements set forth in 34 C.F.R. part 397 regarding students and youth with disabilities who are seeking subminimum wage employment; and
F. Assurance that, in accordance with 34 C.F.R. § 397.31, neither the SEA nor the local educational agency will enter into a contract or other arrangement with an entity, as defined in 34 C.F.R. § 397.5(d), for the purpose of operating a program under which youth with a disability is engaged in work compensated at a subminimum wage.
The formal agreement includes the following:
CONSULTATION AND TECHNICAL ASSISTANCE
Rehabilitation agrees to provide consultation and technical assistance services to WVDE, as well as to LEAs, in order to aid them in the planning for the transition of students with disabilities from school to post-school activities, including pre-employment transition services and other vocational rehabilitation services. Rehabilitation will provide WVDE and LEAs with information, as appropriate, regarding disability awareness, disability etiquette, accommodations and assistive technology, eligibility for Rehabilitation and the application process, vocational rehabilitation services, the availability of community-based services, independent living, competitive integrated employment, and career pathways. Additionally, Rehabilitation will provide consultation and technical assistance to WVDE and LEAs regarding pre-employment transition services including job exploration and labor market information, opportunities for work-based learning experiences, postsecondary enrollment opportunities, workplace readiness training opportunities, and self-advocacy.
Rehabilitation assures that communication with WVDE officials shall be done in the most meaningful and convenient manner possible. To that end, Rehabilitation will provide consultation and technical assistance through a variety of methods, including face-to-face contact, phone calls, email, conference calls, and video conferencing.
TRANSITION AND PRE-EMPLOYMENT TRANSITION SERVICES PLANNING
It is important that WVDE and Rehabilitation work together to determine logistics for providing transition and pre-employment transition services. The IEP and the Individualized Plan for Employment (IPE) must be developed with coordinated goals, objectives, and planned services for effective and successful transition to post-school settings. Each agency will cooperate to provide referral, support, relevant documentation, and assistance to the agency with responsibility for services.
IDEA 2004 and WIOA require the individual's participation in the development of the IEP and IPE, respectively, and emphasize informed choice. Identification of transition services for the IEP is focused on a coordinated set of activities which considers the student's preferences and interests. Likewise, the IPE is developed by a rehabilitation counselor and the individual by identifying goals through reviewing assessments, individual strengths, resources, interests, and needs. WVDE and Rehabilitation provide both awareness and exploration activities in the areas of living, learning, and work to support decisions about post-school outcomes. This interagency cooperation assures the provision of transition and pre-employment transition services that prepare the student to pursue adult goals.
The participation of Rehabilitation counselors, or other Rehabilitation staff, as appropriate, in the IEP process will help students and parents understand the differences in and facilitate the provision of educational and rehabilitation services. To this end, Rehabilitation staff should be invited to IEP meetings, when appropriate, to provide information on available services and eligibility requirements. The Rehabilitation counselor may also assist in the development and coordination between the IEP and the IPE. Both WVDE and Rehabilitation should document any coordinated services outlined in both the IEP and the IPE. Planning, coordinating, and providing transition and pre-employment transition services for students with disabilities may be conducted at the state and local level to maximize service provision and individual choice.
Professional development activities between WVDE and Rehabilitation, when and where appropriate, shall be provided and facilitated by WVDE and/or Rehabilitation staff, including participating in topic-specific learning events and regional support for transition teams.
DETERMINATION OF AGENCY RESPONSIBILITY
Education, through participation in IDEA 2004, has assured the United States Department of Education (USDE) that it has established general supervisory authority over all education programs administered within the State. General supervisory authority means that:
1.	All programs serving eligible students meet all requirements of IDEA 2004;
2.	All programs serving eligible students within the state must meet State standards; and
3.	Funds which support services to eligible school-age students with disabilities, including state and local education funds and funds under Title V, Title VI, Title IX, and Title XX of the Social Security Act, will continue to provide any and all services provided by these funds prior to the passage of IDEA 2004; and no program will alter eligibility requirements for participating in federal, state, and local programs in order to increase the financial responsibility of agencies receiving IDEA 2004 funds. Part B of IDEA does not limit the responsibility of agencies other than educational agencies for providing for and paying for some or all of the costs of FAPE to students with disabilities in the State.
Education has responsibility for providing appropriate special education and related services for each eligible student with a disability, ages 3 to 21, enrolled in the public school system. For each eligible student with a disability at age 14 or younger, if determined appropriate, the transition service needs of the student must be identified, including interagency linkages. Students with disabilities shall have equal access to services that are normally provided by public schools for non-disabled individuals, provided that reasonable accommodations or modifications can be made.
Transition services are defined in IDEA 2004 as a coordinated set of activities for a student with an exceptionality that are designed within a results-oriented process focused on improving the academic and functional achievement of the student to facilitate movement from school to post-school activities including postsecondary education; vocational education; competitive, integrated employment; continuing and adult education; adult services; independent living or community participation.
Rehabilitation is mandated by WIOA, in collaboration with local education agencies (LEAs), including the county-level Boards of Education in each of West Virginia's 55 counties and all public charter schools, to provide or arrange for the provision of pre-employment transition services to students with disabilities (ages 14 through the end of the school year in which the student turns 21) in need of such services who are eligible or potentially eligible for Rehabilitation services--specifically, those students with an IEP and those students with a disability for the purposes of section 504. The five required pre-employment transition service activities are: 1) job exploration counseling; 2) work-based learning experiences; 3) counseling on opportunities for enrollment in comprehensive transition or postsecondary educational programs at institutions of higher education; 4) workplace readiness training; and 5) instruction in self-advocacy.  These services may be provided directly by Rehabilitation staff, school personnel, and/or through Rehabilitation-acknowledged vendors.  Pre-employment transition services may be provided in a group or individual setting.
Rehabilitation is required to conduct, at a local level, a Comprehensive Statewide Needs Assessment (CSNA) to determine the need for the five required pre-employment transition service activities. The CSNA will be used to determine: 1) the level of need for each of the required pre-employment transition service activities, statewide; 2) the amount of service provision delivered by the Education system regarding these five required activities; and 3) the amount of service gap that remains for Rehabilitation to provide. If the student needs one or more of the five required Pre-ETS services that have not already been provided as a transition service under IDEA by the local education agency, Rehabilitation will provide or arrange for the provision of those services.
For students with disabilities, the responsibility for vocational rehabilitation services rests with Rehabilitation. Rehabilitation will provide services, which are legally the responsibility of Rehabilitation, for those individuals determined to be eligible for Rehabilitation services.
Eligibility for Rehabilitation services is determined by the following criteria:
•	An individual must have a permanent physical or mental impairment which, for that individual, constitutes or results in a substantial impediment for employment; and
•	The individual can benefit in terms of a competitive integrated employment outcome from vocational rehabilitation services.
At present, WVDRS has representation in all high schools in all 55 WV counties. WVDRS counselors/staff regularly communicate with local school personnel to promote the awareness and usage of VR services. When permitted, WVDRS school counselors maintain an office in high schools to strengthen the WVDRS resolve to serve students with disabilities (ages 14-21). WVDRS continually sponsors grants and activities to educate all stakeholders in high schools about VR services and employment opportunities for students with disabilities.
The State Education Agency (SEA) and Local Education Agencies (LEAs) have responsibility for providing appropriate special education and related services for each eligible student with a disability, ages 3 to 21, enrolled in the public-school system. For each eligible student with a disability at age 14 or younger, if determined appropriate, the transition service needs of the student must be identified, including interagency linkages. From the perspective of the SEA and LEAs, students with disabilities shall have equal access to services, which are normally provided by public schools for non-disabled individuals, provided that reasonable accommodations or modifications can be made.
It is important that Education and Rehabilitation work together to determine logistics for providing transition services. The IEP and the IPE must be developed with coordinated goals, objectives, and planned services for effective and successful transition to post-school settings. Each agency will cooperate to provide referral, support, and assistance to the agency with responsibility for services.
The formal agreement includes the following: OUTREACH AND IDENTIFICATION
Rehabilitation and Education will utilize a variety of activities to provide outreach to and identification of students with disabilities who are in need of transition and pre-employment transition services. These activities will be conducted both jointly and individually for students with IEPs, students with 504 plans, and other potentially eligible students with disabilities not currently receiving services. Activities may include, but are not limited to, participation in career/job fairs, presentations to students and parents, website links, brochures, surveys, conferencing between Rehabilitation staff and School Counselors, and regularly scheduled contact with individual schools.
Outreach activities and student identification will be conducted as early as possible, preferably no later than the students' 10th grade year and shall include information regarding (1) the purpose of the Rehabilitation program; (2) the eligibility requirements of the Rehabilitation program; (3) the application procedures of the Rehabilitation program; and (4) the scope of services that may be provided by the Rehabilitation program.
The following excerpt from the current formal agreement between WVDRS and WVDE outlines the coordination and documentation requirements, including the provision of Pre-ETS and transition services, for students seeking subminimum wage employment:
"SUBMINIMUM WAGE EMPLOYMENT
Section 511 of the WIOA imposes requirements on WVDE and Rehabilitation with regard to youth with disabilities seeking subminimum wage employment. Rehabilitation and WVDE shall work cooperatively to ensure that the individual, before beginning work that is compensated at a subminimum wage, has completed, and produces documentation indicating completion of, each of the following actions:
1.	The individual has received pre-employment transition services that are available to the individual under section 113, or transition services under the Individuals with Disabilities Education Act (20 U.S.C. 1400 et seq.) such as transition services available to the individual under section 614(d) of that Act (20 U.S.C. 1414(d)).
2.	The individual has applied for vocational rehabilitation services under Title I, with the result that:
1.	the individual has been found ineligible for such services pursuant to that title and has documentation consistent with section 102(a)(5)(C) regarding the determination of ineligibility; or
2.	the individual has been determined to be eligible for vocational rehabilitation services;
3.	the individual has an individualized plan for employment under section 102;
4.	the individual has been working toward an employment outcome specified in such individualized plan for employment, with appropriate supports and services, including supported employment services, for a reasonable period of time without success; and
5.	the individual's vocational rehabilitation case is closed; and
6.	the individual has been provided career counseling and information and referrals to Federal and State programs and other resources in the individual's geographic area that offer employment-related services and supports designed to enable the individual to explore, discover, experience, and attain competitive integrated employment; and
7.	such counseling and information and referrals are not for employment compensated at a subminimum wage provided by an entity described in this subsection, and such employment-related services are not compensated at a subminimum wage and do not directly result in employment compensated at a subminimum wage provided by an entity described in this subsection.
Any student considering subminimum wage employment upon exiting high school should be referred to Rehabilitation. When appropriate, Rehabilitation may request documentation from WVDE for purposes related to this section. Rehabilitation will collect and document the necessary prerequisites, corresponding services, and information (described above) required of individuals (aged 24 and younger) seeking subminimum wage employment. This documentation will be provided to the individual within 45 days after the completion of services, or 90 days if a longer period of time is needed due to extenuating circumstances.
Furthermore, this agreement assures, pursuant to 34 CFR 397.31, that Rehabilitation and WVDE agree not to enter into a contract or other arrangement with an entity for purposes of operating a program in which youth with disabilities are employed at subminimum wage.”
k. Coordination with Employers
In accordance with the requirements in Section 101(a)(11)(E) of the Rehabilitation Act, describe how the VR agency will work with employers to identify competitive integrated employment and career exploration opportunities in order to facilitate the provision of VR services; and transition services for youth and students with disabilities, including pre-employment transition services for students with disabilities.
The West Virginia Division of Rehabilitation Services (WVDRS) believes that coordination with employers is integral to improving the workforce development system. Gathering/collecting information about employer needs, which will also be shared with other Workforce Innovation and Opportunity Act (WIOA) partners, allows WVDRS to provide training and other services to vocational rehabilitation (VR) consumers to meet business needs and expectations of current and future workers. To optimize its coordination with employers to identify competitive integrated employment and career exploration opportunities for consumers with disabilities, WVDRS takes a multifaceted approach. WVDRS utilizes its own personnel in addition to partnering with WorkForce WV to coordinate with employers across the state. Additionally, WVDRS has specific programs/strategies to identify employment and career exploration opportunities for students with disabilities, including the provision of pre-employment transition services (Pre-ETS). The strategies that WVDRS uses are described below.
WVDRS has an in-house Employer Services Section that specializes in providing employers with disability-related information, services, and pre-screened job seekers. The WVDRS Employer Services Section has nine employment specialists that cover all 55 counties in West Virginia. WVDRS’ team of employment specialists provide business owners and employers with critical business options and assistance in staffing, employee retention strategies, education on disability-related issues, job accommodations, and information about financial incentives for employers who hire individuals with disabilities. In fiscal year 2023, employment specialists provided 647 services to 402 employers; coordinated with WorkForce WV; attended statewide and local Business Services Team meetings; participated in rapid response events; attended local workforce development board (WDB) meetings; provided Job Clubs for students with disabilities; and participated in opportunities for collaboration with community colleges, community rehabilitation programs, and other organizations responsive to the workforce needs of businesses.
Sample of services provided to employers:
•	Pre-screened qualified applicants to reduce employers’ cost of recruitment and hiring.
•	Consultation, recommendation, and training for retention of employees who acquire a disability.
•	Technical assistance on the Americans with Disability Act (ADA).
•	Accessibility options and solutions.
•	Employer onsite disability awareness training.
•	Information on tax credits available to employers.
Direct contact with employers is a key strategy to identify competitive integrated employment and career exploration opportunities for VR consumers, including students with disabilities.
Employment Specialists contact employers to identify current and future job openings. To complement this, WVDRS utilizes labor market information provided by WorkForce WV to identify the top employers in each county; contact is always made with the top ten employers in each county. When meeting with employers, employment specialists provide valuable information, including the WVDRS Employer Resource Guide. The resource guide provides the following information:
•	Staffing services;
•	Training programs and incentives for hiring people with disabilities;
•	Financial incentives;
•	Accessibility assessments;
•	Accommodating employees with disabilities;
•	Basic disability etiquette;
•	Attitudinal barriers;
•	Americans with Disabilities Act;
•	Locating a WVDRS office; and
•	Where to find additional resources.
The Employer Services Section inputs information into the WorkForce WV database of each WVDRS-employer interaction with employment specialists. The information collected includes the business name, contact person, and current job openings by occupation. If needed, a referral to the WVDRS Rehabilitation Technology Unit is made to address workplace accommodations. This list is distributed to field staff to potentially match a job-ready VR consumer with a current job opening. Through positive working relationships with employers, including some of the largest in the state, some now send job postings directly to WVDRS’ Employer Services Section.
WVDRS also coordinates with employers through participation and membership in various community and regional organizations. These activities range from employer-specific organizations to public-private partnerships and allow WVDRS to better understand the needs of employers while jointly developing employment-related activities. Some of these partnerships include:
•	Regional Workforce Development Boards;
•	Tri-State Society for Human Resource Management;
•	Chamber of Commerce of Beckley/Raleigh County;
•	Chamber of Commerce of Fayette County;
•	Chamber of Commerce of Jefferson County;
•	Cabell County Family Resource Network;
•	Greater Wheeling Reentry Policy Council;
•	Chamber of Commerce of the Mid-Ohio Valley;
•	Workforce Business Services Units – Fayette, Greenbrier, Mercer, Monroe, Nicholas, Pocahontas, Raleigh, Summers, and Webster counties; and
•	Employment Specialists attend Community Relations Board meetings at the Federal Prisons in Alderson and Beckley.
Another key strategy to coordinate with employers is through collaboration with WorkForce WV, a WIOA core partner. WorkForce WV is the state agency that oversees numerous U.S. Department of Labor programs. This partnership takes place at all levels, including local offices, regional workforce development boards, and state level Interagency Collaboration Team meetings. These partnerships have been of great benefit for West Virginians with disabilities seeking training and employment.
Because of the services it provides, WorkForce WV has the largest database of both job seekers and job openings in the state. WVDRS is able to tap into these resources to identify current employment opportunities for VR consumers, identify needs of employers across the state, and utilize detailed labor market information to assist individuals (including students) with disabilities in identifying future career opportunities. This allows VR consumers to identify potential employment opportunities and any training or other VR services that are required for the job. Additionally, job-ready VR consumers can create an account with WorkForce WV to find employers seeking workers with specific skills they already possess.
In addition to the previously described activities, the Employer Services Section also works with employers to better serve transitioning youth with disabilities, including providing career exploration opportunities for students with disabilities.
Employment specialist services, including Pre-ETS, provided to students with disabilities:
•	POWER job shadowing program,
•	Transition fairs,
•	Job readiness workshops,
•	Job clubs,
•	Interviewing,
•	Resume preparation,
•	Application assistance,
•	Dressing for an interview/employment,
•	Job retention and good work habits,
•	Job search and employer contacts,
•	Assist students in locating employment opportunities and assisting with applying to openings, and
•	Advocating on the student’s behalf to employers when requested by the student.
 
l. Interagency Cooperation with Other Agencies
In accordance with the requirements in Section 101(a)(11)(C) and (K), describe interagency cooperation with and utilization of the services and facilities of agencies and programs that are not carrying out activities through the statewide workforce development system to develop opportunities for community-based employment in integrated settings, to the greatest extent practicable for the following:
1. State programs (designate lead agency(ies) and implementing entity(ies)) carried out under Section 4 of the Assistive Technology Act of 1998;
With respect to state programs carried out under Section 4 of the Assistive Technology Act of 1998, WVDRS has a memorandum of understanding (MOU) with the West Virginia Assistive Technology System (WVATS) of the West Virginia University Center for Excellence in Disabilities (CED). The purpose of this MOU is to delineate the working relationship between WVDRS and the CED in order to provide effective services to individuals with disabilities and their families, ensuring statewide coverage of assistive technology (AT) needs.
CED provides free services, statewide, to individuals of all ages and abilities.  Device demonstrations are available, in the CED office and in the community, for individuals to receive hands-on guidance from knowledgeable CED staff. Device loans are also available to allow individuals to try out a device before purchasing or to use during a short-term disability (up to 30 days). CED provides technical assistance to government agencies, institutions of higher education, industry, and other entities. This technical assistance includes consultation on AT-related programs and service design.  When appropriate, CED provides information and referrals to ensure individuals are connected with available resources relating to disability needs, AT devices, and funding options.
CED also provides professional development and group training around the state. These trainings are customized to increase knowledge, skills, and competencies in AT devices and service delivery.  Popular training topics include:
•	Creating accessible documents
•	Creating accessible PowerPoint presentations
•	AT and transition
•	Switch access basics
•	iPads as AT
•	AT for recreation
•	AT for aging
CED WVATS activities are overseen by a Consumer Advisory Council, of which a WVDRS representative is a member. Similarly, the CED is represented on the West Virginia State Rehabilitation Council, which works closely with WVDRS to help ensure that all West Virginians with disabilities are provided with an equal opportunity to receive the vocational rehabilitation (VR) service(s) for which they are eligible.
The CED also receives partial funding from WVDRS in exchange for direct services to eligible individuals in need of AT that is unavailable directly from WVDRS. WVDRS has an AT unit, which provides AT solutions to eligible individuals with AT needs statewide. With the additional assistance of the CED, assurances are made that high-quality AT solutions can be provided statewide at any time. Additionally, both parties agree to consult with each other on an as-needed basis for atypical cases.
Individuals and families receiving AT services at the CED who are age 14 or older will also receive information on the eligibility requirements for WVDRS and the VR services they provide. If an eligible individual in the VR system requests AT services from the CED, WVDRS staff will make the proper referral. WVDRS will also refer eligible individuals to the CED in the event that WVDRS is unable to provide, through their AT unit, the necessary AT.
2. Programs carried out by the Under Secretary for Rural Development of the Department of Agriculture;
Although WVDRS does not maintain a formal agreement with the U.S. Department of Agriculture (USDA) through the office of the Under Secretary for Rural Development, it provides rehabilitation services (as necessary and as needed) to eligible migrant and seasonal farm workers with disabilities. Another available resource is the WV AgrAbility Project, a USDA-funded program established to assist farmers and farm families who need to find ways to accommodate their disabilities in order to remain active in agriculture.
WVDRS shares the vision of WV AgrAbility that is to enhance the quality of life for farmers, ranchers, and other agricultural workers with disabilities, so that they, their families, and their communities continue to succeed in rural America.  More specifically, “success” may include: gainful employment in production agriculture or a related occupation, access to appropriate assistive technology needed for work and daily living activities, evidence-based information related to the treatment and rehabilitation of disabling conditions, and targeted support for family caregivers of WV AgrAbility customers. WV AgrAbility addresses a wide variety of disabling conditions in agriculture, including, but not limited to:
•	Arthritis
•	Spinal cord injuries/paralysis
•	Back impairments
•	Amputations
•	Brain injury
•	Visual impairments
•	Hearing impairments
•	Disabling diseases
•	Cerebral palsy
•	Respiratory impairments
•	Head injury
WV AgrAbility continues to work with WVDRS in advocating for services for WV farmers.  WV AgrAbility also provides training for allied health professionals on farm culture, how to tailor treatments to the farmer, and using assistive technology on the farm for Vocational Rehabilitation Counselors, Physical Therapists, and Occupational Therapists.  WV AgrAbility continues advocacy efforts with WVDRS, positively impacting WVDRS’ view on agriculture in WV as a viable self-employment option.
If a WV AgrAbility participant becomes a WVDRS consumer, they may receive vocational rehabilitation services to help them reach their employment goal.  Services may include:
•	Evaluation and assistance in purchasing recommended adaptive devices
•	Assistive technology
•	Rehabilitation technology 
•	Home, business, and/or vehicle modification
•	Assistance for vocational training
•	Physical or mental health restoration
•	Self-employment and business-related services, if applicable
3. Non-educational agencies serving out-of-school youth;
WVDRS works with a variety of non-educational agencies serving out-of-school youth. The primary coordinated activities serving this population are with Workforce Innovation and Opportunity Act (WIOA) partners – WorkForce WV and the regional workforce development boards. WVDRS strives to coordinate referrals and services to eligible out-of-school youth served by the WIOA youth programs that are overseen by WorkForce WV and the regional workforce development boards. These partnerships allow for improved service delivery through the blending of resources and expertise among the agencies. For example, sharing costs allows WVDRS and other agencies to enhance outreach efforts, serve increased numbers of out-of-school youth, and improve outcomes for participants.
In addition to WVDRS’ reliance on WIOA partners in serving out-of-school youth, the agency continues to use Community Rehabilitation Programs (CRPs) that have become a WVDRS- acknowledged vendor to support the needs of this population across the state.
4. State use contracting programs;
West Virginia’s State Use Program was created by the Legislature in 1984 and strengthened in 1989. The program allows employment opportunities to be created for citizens with disabilities through nonprofit Community Rehabilitation Programs. The State Use Law allows these programs and their clients to produce commodities and perform services for various state agencies without requiring competitive bidding. Prices charged for these special commodities and services are established by the governor-appointed Committee for the Purchase of Commodities and Services from the Handicapped.
The Governor’s Committee consists of six members appointed by the Governor with the advice and consent of the Senate. One member is selected by the Governor to serve as chairperson. Members represent the following:
•	a private citizen who is conversant with the problems incidental to the employment of persons with disabilities,
•	a representative of a producing nonprofit workshop,
•	a representative of the Division of Rehabilitation Services,
•	a representative of the Department of Administration who is knowledgeable in the purchasing requirements of the state,
•	a representative of private business who is knowledgeable in the activities involved in the sale of commodities or services to governmental entities, and
•	a representative of organized labor who is knowledgeable in matters relating to employment of people with disabilities.
Members serve two-year terms. There is also an ex-officio, non-voting member of the committee who is appointed by the Director of the Purchasing Division. This person serves as the Executive Secretary. There are no geographical or political party constraints on who may be appointed.
The state network of CRPs is critical to the effective and efficient delivery of vocational rehabilitation services to individuals with significant disabilities.  2023, there are 82 WVDRS-acknowledged parent company CRPs in West Virginia located at 85 service sites. Some of these CRPs participate in state use contracting programs. WVDRS maintains working relationships with nonprofit CRPs in West Virginia that provide supported and direct employment, community-based assessment, and/or work skills assessment. CRPs also provide employment readiness services such as life skills and work adjustment, job site training, and trial work experience. While respecting freedom of choice, WVDRS encourages work center programs to expand community-based programs for these individuals. Any CRP meeting the WVDRS acknowledgment process will be permitted under a written Vendor Acknowledgment to bill for services provided to WVDRS consumers. To become a WVDRS-acknowledged vendor, an applicant must request, complete, and return a Vendor Acknowledgment Packet. Upon receipt of the completed packet, a recommendation to acknowledge or not acknowledge will be made to the WVDRS Director.
The Vendor Acknowledgment Packet contains an application for Vendor Acknowledgment to provide supported employment services, an annual data summary that provides the agency’s name, address, contact information, a checklist of those WVDRS services they will be providing, and a Vendor Acknowledgment form addressing conditions of and payment for services rendered to WVDRS consumers.
A signed Vendor Acknowledgment indicates that the vendor agrees to follow conditions set forth regarding standards, antidiscrimination, indemnification, and conditions/standards of operation. The acknowledgment is good for three years.
5. State agency responsible for administering the State Medicaid plan under title XIX of the Social Security Act (42 U.S.C. 1396 et seq.);
WVDRS maintains a memorandum of understanding (MOU) with the West Virginia Department of Health and Human Resources, Bureau for Medical Services (BMS), the state agency responsible for the State Medicaid plan under the Title XIX of the Social Security Act; this is also known as the Waiver program. An advisory group for the program is constituted with the WV Developmental Disability Council (WVDDC). WVDRS has a position on the council. WVDRS and BMS interact as part of this advisory group through the WVDDC. The primary involvement of the Title XIX Medicaid Waiver program in fostering competitive, integrated employment outcomes through vocational rehabilitation is by mandating referral to WVDRS and providing ongoing support funding for those cases closed by WVDRS in Supported Employment. The WVDDC also advises BMS on policy development and meeting unmet needs of those participating in the Title XIX Medicaid Waiver program.
In addition to interacting with Title XIX Medicaid Waiver staff as part of the WVDDC meetings, WVDRS participates in two subcommittees, Employment First and Medley Management. The Employment First committee focuses on promoting employment for intellectually/developmentally disabled (IDD) individuals as a first option among services providers, legislators, state policy makers, and the community at large. The Medley Management committee provides oversight and advice to the West Virginia Department of Health and Human Resources, Bureau for Behavioral Health on the state’s Medley program, which serves a specific group of IDD individuals that are at risk of institutionalization. These are often individuals that are also Title XIX Medicaid Waiver eligible. On both of these committees, WVDRS promotes a focus on competitive, integrated employment outcomes.
WVDRS counselors will, at the time of application, gather information regarding an individual’s third-party resources, including Medicaid. If it is determined that the individual receives Medicaid benefits, BMS will provide all Medicaid-covered services to the individual, regardless of that individual’s continued status with WVDRS. If an individual is approved to receive services from WVDRS and begins to receive Medicaid benefits at a later time, BMS will provide all Medicaid-covered services to the individual from that time forward.
Individuals receiving services from BMS will receive information on the eligibility requirements for WVDRS and the services WVDRS provides. If an individual receiving services from BMS expresses a desire to work, he or she will be referred to WVDRS at that time. Similarly, WVDRS consumers who are Medicaid-eligible will be referred to BMS.
WVDRS also maintains an MOU with the Division of Intellectual and Developmental Disabilities (DIDD), within the West Virginia Department of Health and Human Services, Bureau for Behavioral Health (BBH), the state agency with primary responsibility for providing services and supports for individuals with intellectual disabilities and individuals with developmental disabilities. WVDRS interacts with both BBH and its subsidiary, DIDD.
WVDRS, BBH, and DIDD agree to collaborate to facilitate delivery of services, including extended services, to individuals with the most significant disabilities in the following ways:
•	The DIDD program manager and WVDRS will interact regularly as part of the WVDDC meetings, as well as on the Employment First and Medley Management committees. The Employment First committee focuses on promoting employment for IDD individuals as a first option among services providers, legislators, state policy makers, and the community at large. The Medley Management committee provides oversight and advice to the BBH on the state’s Medley program, which serves a specific group of IDD individuals that are at risk of institutionalization. On these committees, WVDRS promotes a focus on competitive, integrated employment outcomes.
•	The BBH administers several Customized Employment grants with vendors of WVDRS. BBH and WVDRS will jointly train the Community Rehabilitation Programs receiving these grants as well as WVDRS staff working with these programs.
•	BBH and WVDRS will work together in mediating problems in cases being served jointly in the programs.
•	WVDRS will meet monthly with BBH staff to review applicants for an unmet needs funding program to foster assistance to IDD individuals where traditional funding sources do not provide needed supports.
•	Individuals receiving services from BBH or DIDD will receive information on the eligibility requirements for WVDRS and the services WVDRS provides. If an individual receiving services from BBH or DIDD expresses a desire to work, he or she will be referred to WVDRS at that time.
WVDRS collaborates with the BBH and its partners to provide quality and timely vocational rehabilitation services to West Virginians with behavioral health conditions who qualify.
WVDRS and BBH staff regularly attend various meetings to receive program updates which allows for collaboration whenever possible. Examples of meetings include:
•	The Olmstead Council – WVDRS and BBH are both state agencies that are required to participate in quarterly Olmstead Council meetings. Olmstead v. L.C. (1999) is a landmark U.S. Supreme Court decision upholding the civil rights of people with disabilities (including those with behavioral health conditions that result in disability) to receive services and supports in the most integrated setting in the community.
•	BBH and WVDRS are two of the principal state agencies that must have membership on the West Virginia Behavioral Health Planning Council (WVBHPC) and attend quarterly meetings, working together and with others, to accomplish the goals of the council. The WVBHPC is a unified voice that promotes wellness, recovery, and resiliency for all West Virginians. The primary purpose of the WVBHPC is to advocate for and evaluate the provision of community-based behavioral health services.
•	WVDRS and BBH are two of the principal state agencies that must have membership on the West Virginia Statewide Independent Living Council (SILC) and attend quarterly meetings allowing each agency to get program updates and to collaborate wherever possible. The SILC’s mission is to ensure persons who have disabilities have access to community-based resources that promote personal choice and facilitate the achievement of their independent living goals.
6. State agency responsible for providing services for individuals with developmental disabilities;
WVDRS maintains an MOU with the West Virginia Department of Health and Human Resources, Bureau for Medical Services (BMS), the state agency responsible for the State Medicaid plan under the Title XIX of the Social Security Act; this is also known as the Waiver program. An advisory group for the program is constituted with the WVDDC. WVDRS has a position on the council. WVDRS and BMS interact as part of this advisory group through the WVDDC. The primary involvement of the Title XIX Medicaid Waiver program in fostering competitive, integrated employment outcomes through vocational rehabilitation is by mandating referral to WVDRS and providing ongoing support funding for those cases closed by WVDRS in Supported Employment. The WVDDC also advises BMS on policy development with the goal of meeting unmet needs of those participating in the Title XIX Medicaid Waiver program.
In addition to interacting with Title XIX Medicaid Waiver staff as part of the WVDDC meetings, WVDRS participates in two subcommittees, Employment First and Medley Management. The Employment First committee focuses on promoting employment for IDD individuals as a first option among services providers, legislators, state policy makers, and the community at large. The Medley Management committee provides oversight and advice to the West Virginia Department of Health and Human Resources, Bureau for Behavioral Health on the state’s Medley program, which serves a specific group of IDD individuals that are at risk of institutionalization. These individuals are often Title XIX Medicaid Waiver-eligible also. On both committees, WVDRS promotes a focus on competitive, integrated employment outcomes.
7. State agency responsible for providing mental health services; and
The West Virginia Department of Health and Human Services, Bureau for Behavioral Health is the federally designated State Authority for mental health and substance abuse, as well as the lead agency for intellectual and developmental disabilities and provides planning, direction, training and funding for prevention, treatment, and recovery services throughout the state. WVDRS also maintains an MOU with the Division of Intellectual and Developmental Disabilities (DIDD), within the West Virginia Department of Health and Human Services, Bureau for Behavioral Health (BBH). WVDRS interacts with both BBH and its subsidiary, DIDD.
WVDRS, BBH, and DIDD agree to interact in the following ways to facilitate delivery of services, including extended services, to individuals with the most significant disabilities:
•	The BBH administers several Customized Employment grants with vendors of WVDRS. BBH and WVDRS will jointly train the Community Rehabilitation Programs receiving these grants as well as WVDRS staff working with these programs.
•	BBH and WVDRS will work together in mediating problems in cases being served jointly in the programs.
•	Individuals receiving services from BBH or DIDD will receive information on the eligibility requirements for WVDRS and the services WVDRS provides. If an individual receiving services from BBH or DIDD expresses a desire to work, he or she will be referred to WVDRS at that time.
•	WVDRS collaborates with the BBH and its partners to provide quality and timely vocational rehabilitation services to West Virginians with behavioral health conditions who qualify.
WVDRS and BBH regularly attend various meetings together to receive program updates which allows for collaboration whenever possible. Examples of meetings include:
•	The Olmstead Council – WVDRS and BBH are required state agencies that participate in quarterly Olmstead Council meetings. Olmstead v. L.C. (1999) is a landmark U.S. Supreme Court decision upholding the civil rights of people with disabilities (including those with behavioral health conditions that result in disability) to receive services and supports in the most integrated setting in the community.
•	BBH and WVDRS are two of the principal state agencies that must have membership on the West Virginia Behavioral Health Planning Council (WVBHPC) and attend quarterly meetings, working together and with others, to accomplish the goals of the council. The WVBHPC is a unified voice that promotes wellness, recovery, and resiliency for all West Virginians. The primary purpose of the WVBHPC is to advocate for and evaluate the provision of community-based behavioral health services.
•	WVDRS and BBH are two of the principal state agencies that must have membership on the West Virginia Statewide Independent Living Council (SILC) and attend quarterly meetings allowing each agency to get program updates and collaborate wherever possible. The SILC’s mission is to ensure persons who have disabilities have access to community-based resources that promote personal choice and to facilitate the achievement of their independent living goals.
8. Other Federal, State, and local agencies and programs outside the workforce development system.
The West Virginia Division of Rehabilitation Services (WVDRS) maintains cooperation and coordination with various agencies and entities. This section describes WVDRS’ association with agencies or entities that are not in the statewide workforce development system, education officials, private nonprofit vocational rehabilitation service providers, and supported employment and extended services providers for individuals with the most significant disabilities.
WVDRS continues to maintain strong relationships with many agencies and organizations that are not in the statewide workforce development system and whose functions, in some capacity, involve the provision of services to individuals with disabilities. WVDRS’ association with other organizations occurs with varying degrees of involvement depending upon joint initiatives that may be planned and/or that may occur within any given year. Generally, WVDRS representatives may be included in advisory functions for other agencies, as are other agencies with the strategic planning that occurs within WVDRS. Some examples include:
•	A WVDRS representative is actively involved with the West Virginia Behavioral Health Planning Council in the monitoring and oversight of behavioral health services in the state. The WVDRS representative participates in quarterly Council meetings and serves on various subcommittees.
•	WVDRS representatives participate with the West Virginia Developmental Disabilities Council. WVDRS maintains a close working relationship with the staff and members of this Council and has provided support and received effective feedback for its work.
•	WVDRS is partnering with the West Virginia Bureau for Behavioral Health in implementing the pilot project "Enhancing Employment for People with Mental Illness."
•	WVDRS also collaborates with the West Virginia Bureau for Behavioral Health, which involves increasing employment opportunities for individuals in recovery who want to become Peer Recovery Support Specialists through our On-the-Job Training program.
•	WVDRS is represented on the State’s Interagency Collaborative Team (ICT), a group (including agencies not under the state workforce development system) centered around WorkForce WV to provide ongoing attention to addressing issues that will build and continually improve the statewide Workforce Development System (WDS). The team is the single State-level interagency group for addressing issues or concerns regarding building and maintaining the most effective and efficient implementation of the overall WDS in WV. WVDRS participates in and hosts regular, monthly meetings of the ICT, and is one of the signatories of the ICT Memorandum of Understanding, which is drafted annually. The ICT membership includes:	
o	Department of Commerce – WorkForce WV – WV Employment Service
o	Department of Commerce – Division of Rehabilitation Services
o	Department of Commerce – Development Office – Community Development Division
o	Department of Commerce – Development Office – Business Industry Development
o	Bureau of Senior Services – State Unit on Aging
o	Council for Community and Technical College Education
o	Department of Education – Office of Adult Education and Workforce Development
o	Department of Education – Office of Diversion and Transition Programs
o	Department of Health and Human Resources – Bureau of Children and Families
o	Department of Health and Human Resources –Temporary Assistance for Needy Families
o	Department of Health and Human Resources – Food Stamp Employment and Training, United States Department of Agriculture
•	WVDRS has a good working relationship with the Department of Veterans Affairs (VA) at the district level, which allows direct referrals of appropriate veterans from VA facilities to WVDRS’ Rehabilitation Technology Unit for assistive technology and rehabilitation engineering services. Furthermore, WVDRS maintains liaisons for multiple VA offices in WV. WVDRS representatives from one district office also attend the yearly Homeless Veteran Stand Down event to increase outreach to veterans who are unhoused. WVDRS will continue to provide internship opportunities for veterans to increase their knowledge, skills, and abilities which will allow them to be more competitive job seekers.
9. Other private nonprofit organizations.
WVDRS does not work with any private charities or foundations.
However, the state network of nonprofit Community Rehabilitation Programs (CRPs) is critical to the effective and efficient delivery of vocational rehabilitation (VR) services to individuals with significant disabilities. CRPs also provide services, including pre–employment transition services (Pre-ETS), to students with disabilities. As of November 2023, there are 82 WVDRS-acknowledged parent company CRPs in West Virginia located at 85 service sites. There are also an additional 52 Student Transition to Employment Program (STEP) vendors that focus on serving students with disabilities.
WVDRS maintains working relationships with nonprofit CRPs in West Virginia that provide supported and direct employment, community-based assessment, and/or work skills assessment. CRPs also provide employment readiness services such as life skills and work adjustment, job site training, and extended employment assessment. While respecting freedom of choice, WVDRS encourages work center programs to expand community-based programs for these individuals.
Any CRP meeting the WVDRS acknowledgment process will be permitted under a written Vendor Acknowledgment to bill for services provided to WVDRS consumers. To become a WVDRS-acknowledged vendor, an applicant must request, complete, and return a Vendor Acknowledgment Packet. Upon receipt of the completed packet, a recommendation to acknowledge or not acknowledge will be made to the WVDRS Director.
The Vendor Acknowledgment Packet contains an application for Vendor Acknowledgment to provide supported employment services, an annual data summary that provides the agency’s name, address, contact information, a checklist of those WVDRS services they will be providing, and a Vendor Acknowledgment form addressing conditions of and payment for services rendered to WVDRS consumers.
A signed Vendor Acknowledgment indicates that the vendor agrees to follow conditions set forth regarding standards, antidiscrimination, indemnification, and conditions/standards of operation. The acknowledgment is valid for three years.
CRPs can also supplement work exploration activities and provide opportunities for VR consumers, especially students, statewide. WVDRS also utilizes school personnel as CRP vendors as part of STEP. These teacher/vendors work with students outside of school hours to provide them with CRP services such as community-based assessment, work skills assessment, work adjustment training, job placement, and job coaching. The students benefit from working with a trusted adult, who is already familiar with the student’s strengths and weaknesses. This eliminates the need for new and/or additional assessment by the service provider.
Furthermore, this program allows WVDRS to ensure services are available in rural areas. WVDRS has made it an agency goal and priority to expand CRP service availability.
Assurances
The designated State agency or designated State unit, as appropriate and identified in the State certifications included with this VR services portion of the Unified or Combined State Plan and its supplement, through signature of the authorized individual, assures the Commissioner, that it will comply with all of the requirements of the VR services portion of the Unified or Combined State Plan and its supplement, as set forth in sections 101(a) and 606 of the Rehabilitation Act. The individual authorized to submit the VR services portion of the Unified or Combined State Plan and its supplement makes the following assurances:
The VR agency must select the “Edit” button to review and agree to the VR State plan Assurances.
The State Plan must include	
1. Public Comment on Policies and Procedures: The designated State agency assures it will comply with all statutory and regulatory requirements for public participation in the VR Services Portion of the Unified or Combined State Plan, as required by section 101(a)(16)(A) of the Rehabilitation Act.	
2. Submission of the VR services portion of the Unified or Combined State Plan and Its Supplement: The designated State unit assures it will comply with all requirements pertaining to the submission and revisions of the VR services portion of the Unified or Combined State Plan and its supplement for the State Supported Employment Services program, as required by sections 101(a)(1), (22), (23), and 606(a) of the Rehabilitation Act; section 102 of WIOA in the case of the submission of a Unified State plan; section 103 of WIOA in the case of a submission of a Combined State Plan; 34 CFR 76.140.	
3. Administration of the VR services portion of the Unified or Combined State Plan: The designated State agency or designated State unit, as appropriate, assures it will comply with the requirements related to:	
3.a. the establishment of the designated State agency and designated State unit, as required by section 101(a)(2) of the Rehabilitation Act. 	
3.b. either a State independent commission or State Rehabilitation Council, as required by section 101(a)(21) of the Rehabilitation Act.	
3.c. consultations regarding the administration of the VR services portion of the Unified or Combined State Plan, in accordance with section 101(a)(16)(B) of the Rehabilitation Act.	
3.d. the financial participation by the State, or if the State so elects, by the State and local agencies, to provide the amount of the non-Federal share of the cost of carrying out the VR program in accordance with section 101(a)(3).	
3.e. as applicable, the local administration of the VR services portion of the Unified or Combined State Plan, in accordance with section 101(a)(2)(A) of the Rehabilitation Act.	
3.f. as applicable, the shared funding and administration of joint programs, in accordance with section 101(a)(2)(A)(ii) of the Rehabilitation Act.	
3.g. statewideness and waivers of statewideness requirements, as set forth in section 101(a)(4) of the Rehabilitation Act.	
3.h. the requirements for cooperation, collaboration, and coordination, as required by sections 101(a)(11) and (24)(B); and 606(b) of the Rehabilitation Act.	
3.i. all required methods of administration, as required by section 101(a)(6) of the Rehabilitation Act.	
3.j. the requirements for the comprehensive system of personnel development, as set forth in section 101(a)(7) of the Rehabilitation Act.	
3.k. the compilation and submission to the Commissioner of statewide assessments, estimates, State goals and priorities, strategies, and progress reports, as appropriate, and as required by sections 101(a)(15), 105(c)(2), and 606(b)(8) of the Rehabilitation Act.	
3.l. the reservation and use of a portion of the funds allotted to the State under section 110 of the Rehabilitation Act for the development and implementation of innovative approaches to expand and improve the provision of VR services to individuals with disabilities, particularly individuals with the most significant disabilities as set forth in section 101(a)(18)(A).	
3.m. the submission of reports as required by section 101(a)(10) of the Rehabilitation Act.	
4. Administration of the Provision of VR Services: The designated State agency, or designated State unit, as appropriate, assures that it will:	
4.a. comply with all requirements regarding information and referral services in accordance with sections 101(a)(5)(E) and (20) of the Rehabilitation Act.	
4.b. impose no duration of residence requirement as part of determining an individual's eligibility for VR services or that excludes from services under the plan any individual who is present in the State in accordance with section 101(a)(12) of the Rehabilitation Act.	
4.c. provide the full range of services listed in section 103(a) of the Rehabilitation Act as appropriate, to all eligible individuals with disabilities in the State who apply for services or, if implementing an order of selection, in accordance with criteria established by the State for the order of selection as set out in section 101(a)(5) of the Rehabilitation Act.	
4.d. determine whether comparable services and benefits are available to the individual in accordance with section 101(a)(8) of the Rehabilitation Act.	
4.e. comply with the requirements for the development of an individualized plan for employment in accordance with section 102(b) of the Rehabilitation Act.	
4.f. Comply with requirements regarding the provisions of informed choice for all applicants and eligible individuals in accordance with section 102(d) of the Rehabilitation Act	
4.g. provide vocational rehabilitation services to American Indians who are individuals with disabilities residing in the State, in accordance with section 101(a)(13) of the Rehabilitation Act.	
4.h. comply with the requirements for the conduct of semiannual or annual reviews, as appropriate, for individuals employed either in an extended employment setting in a community rehabilitation program or any other employment under section 14(c) of the Fair Labor Standards Act of 1938, as required by sections 101(a)(14) and 511 of the Rehabilitation Act.	
4.i. meet the requirements in sections 101(a)(17) and 103(b)(2) of the Rehabilitation Act if the State elects to construct, under special circumstances, facilities for community rehabilitation programs.	
4.j. With respect to students with disabilities, the State,	
4.j.i. has developed and will implement,	
4.j.i.A. strategies to address the needs identified in the assessments; and	
4.j.i.B. strategies to achieve the goals and priorities identified by the State, to improve and expand vocational rehabilitation services for students with disabilities on a statewide basis; and	
4.j.ii. has developed and will implement strategies to provide pre-employment transition services (sections 101(a)(15), 101(a)(25) and 113).	
4.j.iii. shall reserve not less than 15 percent of the allocated funds for the provision of pre-employment transition services; such funds shall not be used to pay for the administrative costs of providing pre-employment transition services.	
5. Program Administration for the Supported Employment Title VI Supplement to the State plan:	
5.a. The designated State unit assures that it will include in the VR services portion of the Unified or Combined State Plan all information required by section 606 of the Rehabilitation Act.	
5.b. The designated State agency assures that it will submit reports in such form and in accordance with such procedures as the Commissioner may require and collects the information required by section 101(a)(10) of the Rehabilitation Act separately for individuals receiving supported employment services under title I and individuals receiving supported employment services under title VI of the Rehabilitation Act.	
6. Financial Administration of the Supported Employment Program (Title VI):	
6.a. The designated State agency assures that it will expend no more than 2.5 percent of the State's allotment under title VI for administrative costs of carrying out this program; and, the designated State agency or agencies will provide, directly or indirectly through public or private entities, non-Federal contributions in an amount that is not less than 10 percent of the costs of carrying out supported employment services provided to youth with the most significant disabilities with the funds reserved for such purpose under section 603(d) of the Rehabilitation Act, in accordance with section 606(b)(7)(H) and (I) of the Rehabilitation  Act.	
6.b. The designated State agency assures that it will use funds made available under title VI  of the Rehabilitation Act only to provide supported employment services to individuals with the most significant disabilities, including extended services to youth with the most significant disabilities, who are eligible to receive such services; and, that such funds are used only to supplement and not supplant the funds provided under Title I of the Rehabilitation Act, when providing supported employment services specified in the individualized plan for employment, in accordance with section 606(b)(7)(A) and (D), of the Rehabilitation Act.	
7. Provision of Supported Employment Services:	
7.a. The designated State agency assures that it will provide supported employment services as defined in section 7(39) of the Rehabilitation Act.	
7.b. The designated State agency assures that the comprehensive assessment of individuals with significant disabilities conducted under section 102(b)(1) of the Rehabilitation Act and funded under title I of the Rehabilitation Act includes consideration of supported employment as an appropriate employment outcome, in accordance with the requirements of section 606(b)(7)(B) of the Rehabilitation Act an individualized plan for employment that meets the requirements of section 102(b) of the Rehabilitation Act, which is developed and updated with title I funds, in accordance with sections 102(b)(3)(F) and  606(b)(7)(C) and (E) of the Rehabilitation Act.	
Do you attest that these assurances will be met?
Yes
Vocational Rehabilitation (Combined or General) Certifications
States must provide written and signed certifications that:
1. The (enter the name of designated State agency or designated State unit, as appropriate,) is authorized to submit the VR services portion of the Unified or Combined State Plan under title I of the Rehabilitation Act of 1973 (Rehabilitation Act), as amended by title IV of WIOA[1], and its State Plan supplement under title VI of the Rehabilitation Act;
[1]  Public Law 113-128.
Enter the name of designated State agency or designated State unit, as appropriate
West Virginia Division of Rehabilitation Services
2. In the event the designated State agency is not primarily concerned with vocational and other rehabilitation of individuals with disabilities, the designated State agency must include a designated State unit for the VR program (Section 101(a)(2)(B)(ii) of the Rehabilitation Act).  As a condition for the receipt of Federal funds under title I of the Rehabilitation Act for the provision of VR services, the (designated State agency or the designated State unit when the designated State agency has a designated State unit)[2]agrees to operate and is responsible for the administration of the State VR Services Program in accordance with the VR services portion of the Unified or Combined State Plan[3], the Rehabilitation Act, 34 CFR 361.13(b) and (c), and all applicable regulations[4], policies, and procedures established by the Secretary of Education. Funds made available to States under section 111(a) of the Rehabilitation Act are used solely for the provision of VR services and the administration of the VR services portion of the Unified or Combined State Plan;
[2] All references in this plan to "designated State agency" or to "the State agency" relate to the agency identified in this paragraph.
[3] No funds under title I of the Rehabilitation Act may be awarded without an approved VR services portion of the Unified or Combined State Plan in accordance with section 101(a) of the Rehabilitation Act.
[4] Applicable regulations, in part, include the Education Department General Administrative Regulations (EDGAR) in 34 CFR parts 76, 77, 79, 81, and 82; 2 CFR part 200 as adopted by 2 CFR part 3474; and the State VR Services program regulations at 34 C.F.R. part 361.
Enter the name of designated State agency
West Virginia Department of Commerce
3. As a condition for the receipt of Federal funds under title VI of the Rehabilitation Act for supported employment services, the designated State agency, or the designated State unit when the designated State agency has a designated State unit, agrees to operate and is responsible for the administration of the State Supported Employment Services Program in accordance with the supplement to the VR services portion of the Unified or Combined State Plan[5], the Rehabilitation Act, and all applicable regulations[6], policies, and procedures established by the Secretary of Education. Funds made available under title VI are used solely for the provision of supported employment services and the administration of the supplement to the VR services portion of the Unified or Combined State Plan;
[5] No funds under title VI of the Rehabilitation Act may be awarded without an approved supported employment supplement to the VR services portion of the Unified or Combined State Plan in accordance with section 606(a) of the Rehabilitation Act.
[6] Applicable regulations, in part, include the citations in footnote 4, as well as Supported Employment program regulations at 34 C.F.R. part 363.
4. The designated State unit or, if not applicable, the designated State agency has the authority under State law to perform the functions of the State regarding the VR services portion of the Unified or Combined State Plan and its supplement and is responsible for the administration of the VR program in accordance with 34 CFR 361.13(b) and (c);
5. The State legally may carry out each provision of the VR services portion of the Unified or Combined State Plan and its supplement.
6. All provisions of the VR services portion of the Unified or Combined State Plan and its supplement are consistent with State law.
7. The (enter the name of authorized representative below) has the authority under State law to receive, hold, and disburse Federal funds made available under the VR services portion of the Unified or COMBINED STATE Plan and its supplement;
Enter the name of authorized representative below
Pisnu Bua-Iam
8. The (enter the title of authorized representative below) has the authority to submit the VR services portion of the Unified or COMBINED STATE Plan and the supplement for Supported Employment services;
Enter the title of authorized representative below
Director, West Virginia Division of Rehabilitation Services
9. The agency that submits the VR services portion of the Unified or Combined State Plan and its supplement has adopted or otherwise formally approved the plan and its supplement.
Footnotes
[1]  Public Law 113-128.
[2] All references in this plan to "designated State agency" or to "the State agency" relate to the agency identified in this paragraph.
[3] No funds under title I of the Rehabilitation Act may be awarded without an approved VR services portion of the Unified or Combined State Plan in accordance with section 101(a) of the Rehabilitation Act.
[4] Applicable regulations, in part, include the Education Department General Administrative Regulations (EDGAR) in 34 CFR parts 76, 77, 79, 81, and 82; 2 CFR part 200 as adopted by 2 CFR part 3474; and the State VR Services program regulations at 34 C.F.R. part 361.
[5] No funds under title VI of the Rehabilitation Act may be awarded without an approved supported employment supplement to the VR services portion of the Unified or Combined  State Plan in accordance with section 606(a) of the Rehabilitation Act.
[6] Applicable regulations, in part, include the citations in footnote 4, as well as Supported Employment program regulations at 34 C.F.R. part 363.
Certification Signature
To review and complete the Certification section of the VR portion of the State plan, please select the “Edit” button.
Note, please do not edit the table header or formatting. Only edit the table contents.
If you accidentally edit the table headers and structure, open this link to the blank table. You can copy and paste the table into the narrative field, and start over if needed.
Signatory information	Enter Signatory information in this column	
Name of Signatory	Pisnu Bua-Iam	
Title of Signatory	Director, West Virginia Division of Rehabilitation Services	
Date Signed	2/27/2024	
Vocational Rehabilitation Program Performance Indicators
Each State VR program must submit expected levels of performance in its Unified or Combined State Plan and in the two-year modification of that plan. Expected levels of performance for the first two years of a state plan must be submitted in the initial submission of the Unified or Combined State Plan and in the initial submission of the two-year modification of that Plan, for years three and four, as described in 34 CFR § 361.170(a). Expected levels of performance must be stated to the nearest tenth of a percent (XX.X %) or to the nearest whole dollar for median earnings. State VR programs are reminded that the expected levels of performance must be published for public comment prior to plan submission in accordance with state law, regulation, and policy.
After the Unified or Combined State Plan submission, each State VR program must reach agreement with RSA on the negotiated levels of performance for the indicators for each of the first two years of the Unified or Combined State Plan (or for the third and fourth years of the Unified or Combined State Plan during the required two-year modification process) in accordance with WIOA section 116(b)(3)(A)(iv).
RSA will use its statistical adjustment model to derive pre-program year estimated levels of performance for each indicator. Each State VR program and RSA will consider the negotiation factors outlined in WIOA section 116(b)(3)(A)(v) during the negotiation process. Once negotiated levels of performance are agreed upon, each State VR program must incorporate the negotiated levels of performance into the Unified or Combined State Plan and the two-year modification of that plan prior to the plan’s approval (section 116(b)(3)(A)(iv) of WIOA).
Effectiveness in Serving Employers
In the final rule implementing WIOA, the Departments indicated that they would initially implement this indicator in the form of a pilot to test the feasibility and rigor of three proposed approaches. During Program Year (PY) 2022, the Departments initiated the rulemaking process to establish a standard definition of Effectiveness in Serving Employers. States will continue to report two of three proposed approaches until the Departments issue the final rule and implement the indicator.
Performance Indicators	PY 2024 Expected Level	PY 2024 Negotiated Level	PY 2025 Expected Level	PY 2025 Negotiated Level	
Employment (Second Quarter After Exit)	74.1%	74.1%	74.2%	74.2%	
Employment (Fourth Quarter After Exit)	69.6%	69.6%	69.7%	69.7%	
Median Earnings (Second Quarter After Exit) 	$6,529.88	$6,530.00	$6,530.00	$6,830.00	
Credential Attainment Rate 	47.5%	49.0%	47.6%	50.0%	
Measurable Skill Gains 	47.8%	47.8%	47.9%	47.9%	
Effectiveness in Serving Employers 	Not Applicable 1	Not Applicable 1	Not Applicable 1	Not Applicable 1	
1
 The Departments have not issued the final rule defining Effectiveness in Serving Employers. As a result, states will not submit expected levels of performance for this indicator and the Departments will not establish negotiated levels of performance for PYs 2024 and 2025.
GEPA 427 Form Instructions for Application Package - Vocational Rehabilitation
EQUITY FOR STUDENTS, EDUCATORS, AND OTHER PROGRAM BENEFICIARIES
OMB Control Number 1894-0005 Expiration 02/28/2026
Section 427 of the General Education Provisions Act (GEPA) (20 U.S.C. 1228a) applies to a State applicant submitting a state plan for a formula grant from the US Department of Education.  The State applicant is responsible for completing the GEPA Section 427 form that provides a description of the steps the State proposes to take to ensure all program beneficiaries have equitable access to, and participation in, its Federally funded, State-level project or activity. 
GEPA Section 427 Form Instructions for State Applicants
State applicants must respond to the following four questions:
1. Describe how your entity’s existing mission, policies, or commitments ensure equitable access to, and equitable participation in, the proposed project or activity.
2. Based on your proposed project or activity, what barriers may impede equitable access and participation of students, educators, or other beneficiaries?
3. Based on the barriers identified, what steps will you take to address such barriers to equitable access and participation in the proposed project or activity?
4. What is your timeline, including targeted milestones, for addressing these identified barriers?
 
• Applicants identify any barriers that may impede equitable access and participation in the proposed project or activity, including, but not limited to, barriers based on economic disadvantage, gender, race, ethnicity, color, national origin, disability, age, language, migrant status, rural status, homeless status or housing insecurity, pregnancy, parenting, or caregiving status, and sexual orientation.
• Applicants use the associated text box to respond to each question.  However, applicants might have already included some or all this required information in the narrative sections of their applications or their State Plans.  In responding to this requirement, for each question, applicants may provide a cross-reference to the section(s) in their State Plans that includes the information responsive to that question on this form or may restate that information on this form.
• Applicants are not required to have mission statements or policies that align with equity to apply.
• Applicants that have already undertaken steps to address barriers must still provide an explanation and/or description of the steps already taken in each text box, as appropriate, to satisfy the GEPA Section 427 requirement.
• Applicants that believe no barriers exist must still provide an explanation and/or description to each question to validate that perception, as appropriate, to satisfy the GEPA Section 427 requirement.
Please refer to GEPA 427 - Form Instructions for Application Package
1. Describe how your entity’s existing mission, policies, or commitments ensure equitable access to, and equitable participation in, the proposed project or activity.
Section 427 of the General Education Provisions Act (GEPA) (20 U.S.C. 1228a) applies to a State applicant submitting a state plan for a formula grant from the US Department of Education.  The State applicant is responsible for completing the GEPA Section 427 form that provides a description of the steps the State proposes to take to ensure all program beneficiaries have equitable access to, and participation in, its Federally funded, State-level project or activity. 
 GEPA 427 - Form Instructions for Application Package
State applicants must respond to four questions. 
The first of four questions is:
Describe how your entity’s existing mission, policies, or commitments ensure equitable access to, and equitable participation in, the proposed project or activity.
The West Virginia Division of Rehabilitation Services' (WVDRS) mission is, "Together, we enable and empower individuals with disabilities to work and to live independently by providing individualized services to consumers and employers."  The agency's nondiscrimination policy ensures that WVDRS does not discriminate for its programs based on age, sex, religion, disability, and national or ethnic origin. 
To ensure equitable access and participation of students, educators, or other beneficiaries, the agency provides vocational rehabilitation services statewide through 26 local office locations, which includes 6 offices that are co-located with a combined partner. Additionally, DRS has 5 itinerant offices within the regional American Job Center or affiliate office locations and utilizes itinerant locations in the community and in high schools to ensure equitable access to potentially eligible students and applicants across the state.  While transportation may be a barrier for some individuals in the state, WVDRS utilizes Individualized Transportation Solutions (ITS) to ensure access to requesting and receiving Pre-Employment Transition services, applying for vocational rehabilitation (VR) services, including Supported Employment services, and receiving services, as appropriate. This includes providing purchased transportation services and WVDRS staff meeting with individuals virtually and/or in person at a location that meets the needs of potential and current consumers, as appropriate.
Awareness about VR services in the state is accomplished through many methods, including direct communications with school students, educators, family members, agency partners, service providers (including Community Rehabilitation Programs) and other VR stakeholders that continuously inform potential VR consumers about the VR service delivery system.  WVDRS has also created a position to further enhance outreach across the state, focusing on potentially underserved areas and/or populations.  
Based on the agency's applicant and consumer trends (numerically, demographically and geographically), the agency is ensuring equitable access to participation in the VR system in West Virginia.
2. Based on your proposed project or activity, what barriers may impede equitable access and participation of students, educators, or other beneficiaries?
Section 427 of the General Education Provisions Act (GEPA) (20 U.S.C. 1228a) applies to a State applicant submitting a state plan for a formula grant from the US Department of Education.  The State applicant is responsible for completing the GEPA Section 427 form that provides a description of the steps the State proposes to take to ensure all program beneficiaries have equitable access to, and participation in, its Federally funded, State-level project or activity.  
 GEPA 427 - Form Instructions for Application Package
State applicants must respond to four questions. 
The second of four questions is:
Based on your proposed project or activity, what barriers may impede equitable access and participation of students, educators, or other beneficiaries?
The agency has not identified any unaddressed barriers that may impede equitable access and participation of students, educators, or other beneficiaries.
3. Based on the barriers identified, what steps will you take to address such barriers to equitable access and participation in the proposed project or activity?
Section 427 of the General Education Provisions Act (GEPA) (20 U.S.C. 1228a) applies to a State applicant submitting a state plan for a formula grant from the US Department of Education.  The State applicant is responsible for completing the GEPA Section 427 form that provides a description of the steps the State proposes to take to ensure all program beneficiaries have equitable access to, and participation in, its Federally funded, State-level project or activity. 
 GEPA 427 - Form Instructions for Application Package
State applicants must respond to four questions. 
The third of four questions is:
Based on the barriers identified, what steps will you take to address such barriers to equitable access and participation in the proposed project or activity?
The agency has not identified any unaddressed barriers that may impede equitable access and participation of students, educators, or other beneficiaries.
4. What is your timeline, including targeted milestones, for addressing these identified barriers?
Section 427 of the General Education Provisions Act (GEPA) (20 U.S.C. 1228a) applies to a State applicant submitting a state plan for a formula grant from the US Department of Education.  The State applicant is responsible for completing the GEPA Section 427 form that provides a description of the steps the State proposes to take to ensure all program beneficiaries have equitable access to, and participation in, its Federally funded, State-level project or activity. 
 GEPA 427 - Form Instructions for Application Package
State applicants must respond to four questions. 
The final of four questions is:
What is your timeline, including targeted milestones, for addressing these identified barriers?
The agency has not identified any unaddressed barriers that may impede equitable access and participation of students, educators, or other beneficiaries.
GEPA 427 Form Instructions for Application Package - Supported Employment
EQUITY FOR STUDENTS, EDUCATORS, AND OTHER PROGRAM BENEFICIARIES
OMB Control Number 1894-0005 Expiration 02/28/2026
Section 427 of the General Education Provisions Act (GEPA) (20 U.S.C. 1228a) applies to a State applicant submitting a state plan for a formula grant from the US Department of Education.  The State applicant is responsible for completing the GEPA Section 427 form that provides a description of the steps the State proposes to take to ensure all program beneficiaries have equitable access to, and participation in, its Federally funded, State-level project or activity. 
GEPA Section 427 Form Instructions for State Applicants
State applicants must respond to the following four questions:
1. Describe how your entity’s existing mission, policies, or commitments ensure equitable access to, and equitable participation in, the proposed project or activity.
2. Based on your proposed project or activity, what barriers may impede equitable access and participation of students, educators, or other beneficiaries?
3. Based on the barriers identified, what steps will you take to address such barriers to equitable access and participation in the proposed project or activity?
4. What is your timeline, including targeted milestones, for addressing these identified barriers?
 
• Applicants identify any barriers that may impede equitable access and participation in the proposed project or activity, including, but not limited to, barriers based on economic disadvantage, gender, race, ethnicity, color, national origin, disability, age, language, migrant status, rural status, homeless status or housing insecurity, pregnancy, parenting, or caregiving status, and sexual orientation.
• Applicants use the associated text box to respond to each question.  However, applicants might have already included some or all this required information in the narrative sections of their applications or their State Plans.  In responding to this requirement, for each question, applicants may provide a cross-reference to the section(s) in their State Plans that includes the information responsive to that question on this form or may restate that information on this form.
• Applicants are not required to have mission statements or policies that align with equity to apply.
• Applicants that have already undertaken steps to address barriers must still provide an explanation and/or description of the steps already taken in each text box, as appropriate, to satisfy the GEPA Section 427 requirement.
• Applicants that believe no barriers exist must still provide an explanation and/or description to each question to validate that perception, as appropriate, to satisfy the GEPA Section 427 requirement.
Please refer to GEPA 427 - Form Instructions for Application Package
1. Describe how your entity’s existing mission, policies, or commitments ensure equitable access to, and equitable participation in, the proposed project or activity.
Section 427 of the General Education Provisions Act (GEPA) (20 U.S.C. 1228a) applies to a State applicant submitting a state plan for a formula grant from the US Department of Education.  The State applicant is responsible for completing the GEPA Section 427 form that provides a description of the steps the State proposes to take to ensure all program beneficiaries have equitable access to, and participation in, its Federally funded, State-level project or activity. 
 GEPA 427 - Form Instructions for Application Package
State applicants must respond to four questions. 
The first of four questions is:
Describe how your entity’s existing mission, policies, or commitments ensure equitable access to, and equitable participation in, the proposed project or activity.
The West Virginia Division of Rehabilitation Services' (WVDRS) mission is, "Together, we enable and empower individuals with disabilities to work and to live independently by providing individualized services to consumers and employers."  The agency's nondiscrimination policy ensures that WVDRS does not discriminate for its programs based on age, sex, religion, disability, and national or ethnic origin. 
To ensure equitable access and participation of students, educators, or other beneficiaries, the agency provides vocational rehabilitation services statewide through 26 local office locations, which includes 6 offices that are co-located with a combined partner. Additionally, DRS has 5 itinerant offices within the regional American Job Center or affiliate office locations and utilizes itinerant locations in the community and in high schools to ensure equitable access to potentially eligible students and applicants across the state.  While transportation may be a barrier for some individuals in the state, WVDRS utilizes Individualized Transportation Solutions (ITS) to ensure access to requesting and receiving Pre-Employment Transition services, applying for vocational rehabilitation (VR) services, including Supported Employment services, and receiving services, as appropriate. This includes providing purchased transportation services and WVDRS staff meeting with individuals virtually and/or in person at a location that meets the needs of potential and current consumers, as appropriate.
Awareness about VR services in the state is accomplished through many methods, including direct communications with school students, educators, family members, agency partners, service providers (including Community Rehabilitation Programs) and other VR stakeholders that continuously inform potential VR consumers about the VR service delivery system.  WVDRS has also created a position to further enhance outreach across the state, focusing on potentially underserved areas and/or populations.  
Based on the agency's applicant and consumer trends (numerically, demographically and geographically), the agency is ensuring equitable access to participation in the VR system in West Virginia.
2. Based on your proposed project or activity, what barriers may impede equitable access and participation of students, educators, or other beneficiaries?
Section 427 of the General Education Provisions Act (GEPA) (20 U.S.C. 1228a) applies to a State applicant submitting a state plan for a formula grant from the US Department of Education.  The State applicant is responsible for completing the GEPA Section 427 form that provides a description of the steps the State proposes to take to ensure all program beneficiaries have equitable access to, and participation in, its Federally funded, State-level project or activity.  
 GEPA 427 - Form Instructions for Application Package
State applicants must respond to four questions. 
The second of four questions is:
Based on your proposed project or activity, what barriers may impede equitable access and participation of students, educators, or other beneficiaries?
The agency has not identified any unaddressed barriers that may impede equitable access and participation of students, educators, or other beneficiaries.
3. Based on the barriers identified, what steps will you take to address such barriers to equitable access and participation in the proposed project or activity?
Section 427 of the General Education Provisions Act (GEPA) (20 U.S.C. 1228a) applies to a State applicant submitting a state plan for a formula grant from the US Department of Education.  The State applicant is responsible for completing the GEPA Section 427 form that provides a description of the steps the State proposes to take to ensure all program beneficiaries have equitable access to, and participation in, its Federally funded, State-level project or activity. 
 GEPA 427 - Form Instructions for Application Package
State applicants must respond to four questions. 
The third of four questions is:
Based on the barriers identified, what steps will you take to address such barriers to equitable access and participation in the proposed project or activity?
The agency has not identified any unaddressed barriers that may impede equitable access and participation of students, educators, or other beneficiaries.
4. What is your timeline, including targeted milestones, for addressing these identified barriers?
Section 427 of the General Education Provisions Act (GEPA) (20 U.S.C. 1228a) applies to a State applicant submitting a state plan for a formula grant from the US Department of Education.  The State applicant is responsible for completing the GEPA Section 427 form that provides a description of the steps the State proposes to take to ensure all program beneficiaries have equitable access to, and participation in, its Federally funded, State-level project or activity. 
 GEPA 427 - Form Instructions for Application Package
State applicants must respond to four questions. 
The final of four questions is:
What is your timeline, including targeted milestones, for addressing these identified barriers?
The agency has not identified any unaddressed barriers that may impede equitable access and participation of students, educators, or other beneficiaries.