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Policy and Systemic Influence

07/2007

Customized Employment and Workforce Action grants were charged with conducting model demonstrations of individual-level service delivery as well as creating systems change within their local communities and/or states. As sites began to demonstrate the effectiveness of both Customized Employment practices with individuals with disabilities and universal design within the Workforce Development System, stakeholders looked at ways to make services available to a broader population and to institutionalize the approaches beyond the grants' lifespans.

The issue of policy change was a significant challenge to most grantees. The first and most important step they took was to thoroughly understand what the current policies allowed and the latitude they might be allowed to alter or affect them. Research and data collection were also key elements of this effort, ensuring that new policies were broadly beneficial in the reality of service delivery. To effect policy change, sites needed time and information to develop a comprehensive plan to address obstacles to collaboration and other quality employment service efforts. Grantees also put considerable effort into staff development and examining performance-measurement systems to ensure continuation of strategies after the grant ended.

Key Findings

Local Flexibility

Local systems had considerable control and flexibility when it came to service provision, and project coordinators worked with Local Workforce Investment Boards (LWIBs) to exercise this control effectively. Many sites were able to negotiate more flexible processes for joint service provision and funding with mandated partners than existed in other parts of their states. Individual success stories created an atmosphere of openness and flexibility towards developing policies that could be applied more broadly.

One partnership established an advanced referral system that combined the resources of the Customized Employment grant with those of the Social Security Benefits Planning, Assistance, and Outreach (BPAO) Program, resulting in easier access for customers needing basic SSI/DI information. In addition, the new referral system expedited the process of benefits planning for individuals who needed more extensive information. One LWIB made a policy change allowing part-time workers to be eligible for on-the-job training services that previously had been available only to full-time workers. Another site revised case-management practices and policies related to One-Stop operator testing and assessment, incorporating more flexibility and a wider range of assessment tools, thereby increasing access and effectiveness for a wider range of customers.

Some projects created or revised positions that would serve individuals during the life of the grant and continue when grant funding ceased. Project staff of one grantee utilized Customized Employment strategies to create a car-repair and purchase program with self-directed funds that provided individuals with reliable, consistent transportation used to obtain and maintain employment. By successfully observing and addressing these individual, site-specific issues, grantees were able to create examples on which to base broader change.

Systemic Policy Changes

To achieve systemic change beyond the funding cycle of the project, sites communicated expectations to staff, operators, and vendors for the provision of Customized Employment services. Some partnerships formed agreements with rehabilitation providers that outlined a standardized timeline for the provision of discovery/job seeker exploration services and the development of a vocational profile. Others worked toward the establishment of an operator-certification process based on Customized Employment guidelines and accessibility of services for all customers. A policy was developed by one partnership that made employment the initial consideration for people with disabilities and focused on Customized Employment services delivered by community partners, the school system, the Workforce system, Vocational Rehabilitation (VR), the Department of Developmental Disabilities, and mental health service providers.

An agreement was developed through a Workforce Action grantee to create a milestone-payment system for VR services. The first installment was paid when an individual got a job. The second payment came when the person had maintained his or her job for five days, the third at 30 days, and the fourth at 90 days. The project built a long-standing employment program for individuals with significant mental illness in a catchment area where no such service had existed before. By setting up agreements and communicating clearly with all involved parties; partnerships were able to instill Customized Employment standards more effectively and universally.

Building Capacity

All sites provided training opportunities for staff, including in-person options, distance education, and mentoring. To ensure that staff integrated this training into their work performance, several sites built expectations into their annual reviews concerning staff competencies when serving customers with disabilities. In many cases, frontline One-Stop staff were required to attend a series of trainings/workshops to enhance their capacity to provide Customized Employment services and to become certified in Workforce development areas. The popularity of this type of training led one community college to offer a non-credit certificate course on advanced job development using Customized Employment strategies. The course runs four times a year and has continued in the absence of grant funding.

Job developers from the One-Stop at another locale faced a number of issues with populations they did not previously have expertise with and/or experience serving. The project implemented 12 months of job-developer training that included information and resources on how to assist ex-offenders, many of whom had learning disabilities, mental health, or substance-abuse issues. One-Stop job developers also engaged in more intensive peer-support and technical-assistance activities, such as participation in Customized Works! Employment-planning meetings for specific customers. These approaches provided the job developers with mentoring and skill-development that helped them serve their own customers with barriers to employment.

Multilevel Systems Change

Policy change must occur at multiple levels to be effective. Sites were able to influence local policy and practices as well as address policy barriers at the state level. At one site, staff worked to inform state legislature of issues of income limits for nursing home residents, which led to the state House of Representatives passing a resolution requiring a study of this issue. Another partnership compared all vocational activities provided by community mental health centers with the Mental Health Medicaid Rehabilitation Option (Medicaid Rehab Rule) to determine which Customized Employment activities were billable and, in turn, encourage community mental health programs to use the model. A project manager's efforts in another state led VR to create a new line item code titled "supported self-employment." This new classification allowed VR to support entrepreneurs with disabilities by using creative funding to offset company start-up costs and job-coaching needs.

In an ongoing effort to integrate an "employment first" policy and use the experiences of the grant to foster lasting systems change around Customized Employment, one site sponsored a commissioner's work group with representation from the Department of Human Resources, Department of Labor, VR, Department of Education, Medicaid, Developmental Disabilities Council, University Center for Excellence, and the state Protection and Advocacy organization. Similarly, another state created an Employment System Transformation Steering Committee, consisting of a broad range of state agencies, which helped initiate a comprehensive examination of the employment service system for persons with disabilities. One outcome of this committee was a pilot project that used Customized Employment in the state-government hiring process.

Local Performance Standards

Prior to implementation of the grants, Workforce system personnel - from staff at the front desk to management to the local board - perceived customers with disabilities as being "difficult to serve." This belief could cause staff to be hesitant to enroll customers with disabilities in the WIA system for fear of negative employment/performance outcomes. Several sites established local standards for performance and provision of services to individuals with disabilities to address this concern. One strategy was to increase the percentage of job seekers with disabilities required to be served through the system. Another was to revise service levels for "special populations" and assist One-Stops with the provision of these service levels with additional funds. One-Stops that failed to meet this plan and its requirements would eventually be decertified. This provided the required impetus for local sites to remain vigilant in their training and in serving a wide range of job seekers in their community.

An "investment grid" was developed by one LWIB to establish a more precise system of communicating the board's commitment to serving populations with more significant barriers to employment, and for the development of jobs considered particularly valuable to the local economy. Customers who had received the most support received high point values. Placing a job seeker from a special population (e.g., an individual with a disability) into a job with a priority status (e.g., health care or information technology) received the highest point value. The grid was proposed as a conceptual model for One-Stop and partner performance measures. Steps were also being taken to enforce the grid's standards as LWIB policy and to hold provider systems accountable to the priorities it established.

Systemic Change: Challenges and Strategies

Advancing from Grant Implementation to Systems Change

While all the grants were charged with systems change, some sites were more successful in moving this agenda forward, often due to the way they originally designed and implemented the grant. Sites that were less effective in systems change had set up their services as a separate program less integrated into the operations of the One-Stop as a whole. Where services were more integrated, One-Stop staff and partners were also more likely to see the Customized Employment strategies demonstrated as being relevant to their customer populations.

A number of projects were very conscious about integrating Customized Employment efforts into the options offered at the One-Stop. Although there were One-Stop staff specifically assigned to work with eligible candidates, these staff members used the range of One-Stop options and worked to make all services responsive to all customers, including those with disabilities. One One-Stop manager reported on how this effort made the center rethink how it provided services to all its customers, saying that it "now does business differently."

Data Required to Inform/Influence Decision-Makers

To influence systems change, sites found they needed to provide decision-makers with data to support their proposals. Sites also discovered that previous methods of collection did not always represent disability-related data in a valid and reliable way. As a result, they worked to identify why this data seemed to be underreported and other approaches they might employ to track usage by individuals with disabilities.

Sites approached data collection from many different angles. One partnership developed their strategic plan based on an extensive qualitative-data-collection effort that included input from over 200 community members. Another site worked with the local university to implement a rigorous data-collection system that tracked services to transition-age youth in the county. Not only was this data system effective in identifying services that contributed to employment success, it also tracked individuals who did not obtain employment. This information contributed to a change in outreach efforts to engage out-of-school youth and ensure that schools considered employment for all students, even those with more significant disabilities. Other sites found that they were able to collect more relevant data by adding to existent data-tracking systems, expanding questions on customer characteristics, the provision of Customized Employment services, employment outcomes, and retention.

A resource list implemented through one site was not originally considered a data-collection effort, but over time the project realized that the list was providing important information about resource allocation. The project had developed the resource list to help all customers identify areas of potential need, so that staff could make appropriate referrals to partners. When they began to work with the One-Stop, individuals were asked to complete a checklist that included employment supports such as assistance with job search or training, as well as other needed resources, including housing, day care, and medical insurance. When the information from these forms was aggregated, the WIB could identify the needs of its customers and locate potential areas where resources were insufficient.

Need for Policies to Support Customized Services

One-Stops are typically designed to handle a large customer flow, with self-service and standardized practices the preferred mechanisms for customers to meet their employment needs. To ensure that One-Stops were equipped to allow service customization beyond the grant-funded period, grantees worked with their LWIBs, One-Stop operators, and VR programs to ensure that their policies reflected these expanded services. Sites revised their policies to allow more customization, using formula funds and customer-centered strategies. Testing and assessment policies were modified to reflect the array of alternatives to the typical standardized assessment tools and practices. Case-management policies were also adjusted to allow for the provision of Customized Support Teams or other approaches divergent from the traditional case-management model.

VR policies were modified through the work of one grantee into an expansion of the services then offered. Project personnel worked with VR leadership to incorporate Customized Employment into VR services and policies. Cost-sharing occurred by developing Purchase of Service Agreements (POSAs) between VR and specific, qualified community providers who were competent in Customized Employment services. Thereafter, the local VR absorbed the cost of service for eligible individuals who required Customized Employment strategies to obtain employment. This clearly had mutual benefits, as VR customers were able to attain employment opportunities not previously realized.

Need for State-Level Changes Reflecting the Reality of Local Implementation

Some sites struggled with state-level directives that either did not consider their local communities' needs or were unnecessarily cumbersome to implement. To address this concern, several sites made sure that staff who were directly involved in grant implementation were also involved in state-level-systems change efforts. Bringing a local perspective to state-level decision-making was effective in achieving systems change that addressed both state and local concerns.

Grant staff in one area worked closely with other state-systems change efforts to increase the focus on and commitment to the employment of people with disabilities at the state- agency level. In conjunction with the state Medicaid Infrastructure Grant, they conducted an analysis of Executive Office of Health and Human Services funding for employment services. Participation on the strategic-planning team provided an important opportunity to influence the process.

Local Entities Underestimate the Control They Have in Developing Policy

Although WIA calls for local flexibility and control so that services can be designed to respond to the local community, many staff members felt constrained by state and federal policies. In some cases, there was an assumption that because practices had been in place for a long period that they must be based on official policy. As sites started to look more closely at some of these "policies" that were creating barriers to creativity and innovation, they began to understand that there were sometimes fewer constraints than they had imagined.

Several sites found the Test for Adult Basic Education (TABE) evaluation, when required for individuals to participate in training, was a barrier for customers with disabilities. They therefore explored the possibility of substituting a vocational profile for TABE and using that profile as supplemental evidence for the viability of an employment goal within the VR system. Other sites found flexibility in policy development through contracting processes with partners. Still others came to recognize that long-standing practices were not actually rooted in policy at all.

Barriers in Program and Service Accessibility

Workforce development systems often struggle to help customers with various abilities, learning styles, and barriers benefit from the programs and services available at and through One-Stops. By applying the principles and concepts of universal design to the Workforce system, the grantees promoted ease of use and meaningful access to employment services and opportunities.

In one state, local universal-access assessments and work groups made up of service providers, One-Stop staff, advocates, and consumers, were established to review accessibility issues. In a similar approach, accessibility audits were conducted of One-Stop facilities, programs, and services at the onset of the project. Recommendations and subsequent modifications were then made to core services to benefit various learning styles; to intake and registration practices and procedures; to written products, such as the calendar of events and marketing brochures; and to labels and other visual aids within the resource room. At one site, these findings were collected into a full report with recommendations, highlighting strategies to enhance the system's usability by a diverse range of customers. As a result of these efforts, One-Stop policies began to incorporate universal access into their mandatory policies statewide.

Integrating universal design into a One-Stop's programs and services took one step forward through the development of a PowerPoint "Information Exchange" presentation, which was shared with all new customers during the orientation process. The presentation informed customers of the array of employment services available, including those specific to given populations, and included information on disclosure of disability, confidentiality policies, and the availability of assistive technology at the One-Stop. Also, workshop information was presented in various formats to accommodate a variety of people, whether they had a learning disability, limited English fluency, or a low literacy level.

Recommendations

Come to a clear understanding of policies and each leader's latitude within them.

Before seeking to change a policy that presents a perceived barrier to progress, local systems should first understand the policy and their own ability to operate flexibly within its context. Designated staff should have a clear sense of:

The need to understand the point of control is highly relevant to policy considerations. It is often overlooked in relation to a local system's view of its role in decisions around funding, performance measures, and other important policy features.

Proactively manage performance measures and craft them to expect excellence over compliance.

Local control of performance-measurement policy should be exercised to the greatest extent possible to meet the needs of the local systems and customers. As with other policy concerns, local areas often underestimate the degree of flexibility they have in determining and meeting performance measures.

Rather than pursuing measures that lower expectations for certain groups (i.e., using "regressive measures," which allow lower measures for people with disabilities or other barriers), local areas should seek to establish progressive measures that demand more of the system serving these individuals and then reward this effort accordingly. Examples of this strategy involve WIBs either rewarding service providers for providing the more intensive services needed, or requiring that services to these groups be sufficient to bring them success. As federal policy around performance measures is largely measured in "bulk" terms, it is typically possible to provide a wide range of services to a wide range of individuals and not see a negative effect on the sum performance results of a local area.

Leverage the vendor- and operator-certification process to emphasize desired outcomes.

The operator Request for Proposal (RFP) process allows the LWIB to define those services and populations it views as critical and to articulate expectations in meeting the needs of the chosen populations. Since the operator is evaluated based on these articulated outcomes, the RFP gives the LWIB an accountability system. Training vendors also need to be sent clear messages about the expectations for serving individuals with disabilities. Certification processes can encourage the creative and progressive use of individual and on-the-job training funds to better answer the needs of individual job seekers who require nontraditional services and training resources.

Collect data that reflects the future and present goals of the system, which can potentially validate progressive efforts.

At a local level, systems focusing on progressive work should collect data that reflects their successes and resonates with the standards of their own system as well as those of their major partners, where possible. Specialized grant projects tend to report information in keeping with the goals of the grant, without determining how those outcomes compare with standard system measures. This data should also be utilized in policy development. Basing policy efforts on hard data can effectively convince those less invested in the policy. It also provides a framework to judge the effectiveness of the policy.

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