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Review of State Plans for the Workforce Investment Act from a Disability Policy Framework


The Rehabilitation Research and Training Center on Workforce Investment and Employment Policy for Persons with Disabilities (RRTC) has conducted a review of the state plans mandated under the Workforce Investment Act (Public Law 105-220). The purpose of the review was to establish a research baseline for evaluating current and future state implementation efforts to provide effective and meaningful participation of individuals with disabilities.

The RRTC conducted a review of the WIA state plans submitted by each of the fifty states and the District of Columbia using an analytic framework. Two policy documents were used to guide the review: (1) The Emerging Disability Policy Framework: A Guidepost for Analyzing Public Policy, and (2) A Description of the Workforce Investment Act Legal Framework from a Disability Policy Perspective. Both documents were written by Bobby Silverstein, Director of the Center for the Study and Advancement of Disability Policy, as part of research conducted jointly by the RRTC and the Center for the Study and Advancement of Disability Policy.

The Emerging Disability Policy Framework is intended as a benchmark for both designing and evaluating public policy that seeks to address the needs of Americans with disabilities. It is the result of extensive review of the hearing records, committee reports, statutory and regulatory bases for the Americans with Disabilities Act, the Developmental Disabilities Assistance and Bill of Rights Act, and the Individuals with Disabilities Education Act. The purpose of the review was to discern the fundamental values, principles, and policies inherent in these laws and the extent to which they define the fundamental goals of disability policy. In order to validate the Emerging Disability Policy Framework, analyses and interpretations were subject to peer review by key stakeholders in the outcomes of disability policy: federal, state and local policy makers; persons with disabilities, their families, and advocates; researchers; service providers; and other experts in disability policy. The Emerging Disability Policy Framework includes general questions for analyzing the extent to which disability-specific and generic programs and policies reflect the goals of disability policy in their precepts, goals, definitions, core policies, methods of administration, and program supports. These questions serve as a guide for evaluating, expanding, and improving the design and implementation of public policies affecting persons with disabilities. To that end, the Emerging Disability Policy Framework provides a framework that can be used to design, implement, and evaluate public policies and programs to ensure meaningful inclusion of people with disabilities in mainstream society.

Using the Emerging Disability Policy Framework as its basis, the RRTC developed a Template for analyzing each state plan to identify specific approaches, activities, policies, procedures, and strategies related to effective and meaningful participation by persons with disabilities in the system proposed by that state. The Template covers the state plan development process, a state's vision and goals, and specific provisions related to governance, service delivery, and performance measurement. It includes 35 questions across 14 discrete areas of analysis. Some questions included in the Template are based on specific citations in the law and regulations related to the inclusion of persons with disabilities. Other questions are included to gather a better understanding of how the interests and needs of persons with disabilities will be met under a comprehensive workforce development system mandated under Title I of the Workforce Investment Act.

The Template also allows for a description of how each state addresses the needs of customers with disabilities within each of the 14 discrete areas of analysis. For example, some states simply include "persons with disabilities and/or multiple barriers to employment" as part of a list of all customer groups that would be served but provide no further explanation as to how they would meet the needs of specific groups. Other states provide more comprehensive descriptions of how their state will address the needs of particular customer groups, including persons with disabilities and/or multiple barriers to employment. The design and format of the Template facilitated this level of analysis.

FINDINGS: In order to receive federal financial assistance under the Workforce Investment Act, a state must submit to the U.S. Department of Labor a state plan. A key role for the Department of Labor is state plan approval, including approval of state performance indicators. (Section 1125(c) and 136(g) of WIA (29 USC 2822(c)). An additional role for DOL is leadership, including guidance on interpretations of statutory and regulatory provisions. (Section 189 of WIA (29 USC 2939). A further role for DOL is a monitoring and oversight authority to hold states accountable for performance based on their individual plans and WIA statutory and regulatory requirements.

The review of state plans provides a snapshot, at one point in time, of state specific approaches, policies, procedures, and proposed strategies for effective and meaningful participation by youth and working-age adults with disabilities in the proposed system of workforce development. The review of state plans resulted in five general findings. Additionally, there are 23 specific findings identified across eight core areas of focus: plan development and governance, definitions, state assessment, strategies for improvement, state level performance measurements, local governance and service delivery, youth activities and state monitoring and enforcement.

General Findings

  1. The plans as a group vary significantly in their comprehensive narrative descriptions of core areas of focused analysis: policy goals, program design, interagency collaboration and performance accountability.
  2. Individual plans were inconsistent in their attention to detail across the fourteen areas analyzed through the Disability Policy lens.
  3. However, within specific sections of individual plans, there were detailed descriptions of policies, practices, and proposed strategies to include persons with disabilities and public and private agencies representing service to persons with disabilities in the governance, service delivery design, and continuous program improvement process of the workforce development system.
  4. There was a relationship between the degree that federal plan development guidelines require states to describe in detail proposed procedures or activities and the nature and scope of detailed descriptions provided by states in specific sections of their plans.
  5. More than 80% of the state plans include persons with disabilities and/or representatives of public and private agencies, such as vocational rehabilitation programs, that serve persons with disabilities in the state plan development process. However, the majority of plans did not describe in detail the nature and scope of their involvement.

Selected Specific Findings

  1. None of the State Plans include a definition of disability. Forty-seven states, while not including a definition of disability, do make reference to different types of disabilities.
  2. Only nine states include a description of how they will collect data and track performance on persons with disabilities.
  3. Twenty-five states mention strategies, such as technical assistance, training, and professional development, for improving the capacity of One-Stops to develop and manage effective programs for individuals with disabilities. However, only four of the twenty-five states provided an in-depth explanation of their strategies for support of individuals with disabilities.
  4. Twenty-three states say that they will use technology that is accessible for persons with disabilities. However, only nine of the twenty-three states provide an in-depth explanation about their strategy or approach to the use of accessible technology for persons with disabilities.
  5. Forty-nine states describe a system approach that offers youth, including youth with disabilities, a range of coordinated services. However, only six of the forty-one states provided an in-depth explanation of their system approach of coordinated services for youth with disabilities.

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Robert Silverstein

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