Public Comment on Georgia Vocational Rehabilitation Agency Proposed Policy Revisions Regarding Post-Secondary Academic and Vocational Training

March 23, 2018

Georgia State Rehabilitation Council
ATTN: Interim SRC Liaison Ms. Robin Blount
200 Piedmont Avenue, 5th Floor
Atlanta, Georgia 30338
RE: Public Comment on Georgia Vocational Rehabilitation Agency Proposed Policy Revisions Regarding Post-Secondary Academic and Vocational Training

To the Georgia State Rehabilitation Council:

For the past eight years, the Georgia Council on Developmental Disabilities has worked to promote opportunities for students with intellectual/developmental disabilities to have opportunities to attend inclusive post-secondary education institutions. When this initiative began, we knew that it would not be easy and that we would run into many obstacles along the way. But we were excited by the response we received by colleges, universities, technical schools, students, families, and teachers.

The success of the Inclusive Post-Secondary Education programs has happened because of the collaboration between the higher education institutions, GCDD, the Center for Leadership in Disability at Georgia State University and Georgia Vocational Rehabilitation Agency. Getting a higher education supports the GVRA mission to increase the employment and independence for Georgians with disabilities. The Workforce Innovation and Opportunity Act (WIOA) mandates that agencies such as GVRA focus its efforts on pre-employment transition services such as inclusive post-secondary education. As the agency who worked to begin these programs and have watched them grow, we have seen the benefits of increased independence and productivity afforded the students participating in these programs.

During the 2017 legislative session, we were excited to announce the move of all dollars from GCDD to GVRA in anticipation of increased funding for this initiative. We believed that is move and GVRA's current policy provided the IPSE programs a positive resource and ensures access for IPSE students with a sustainable plan for future. This access and sustainability has been possible because the current policy allows for GVRA to financially support qualified individuals to attend an IPSE program if the program has earned the US Department of Education's federal designation as a Comprehensive Transition Program (CTP). All current eight IPASE programs either have received CTP designation or are working to receive that designation.

To our knowledge, the federal government in awarding CTP designation does not require schools to award students a certification, diploma, or degree and rather regards this accreditation as sufficient evidence or rigor in order to merit that the CTP be regarded as a meaningful credential. GCDD asks that you consider editing the language in the proposed policy changes to CTP programs to remove the narrow and specific language that requires credentials be based on "measurable technical or industry/ occupational skills necessary to obtain employment or advance within an industry/ occupation", specifically including "industry-recognized certificate or certification ... or an associate, baccalaureate, or graduate degree". Given this narrow definition of recognized credential (which is more specific than the publicly stated WIOA performance measure regarding credential), students of lower socio-economic status will be disproportionately limited in their ability to choose an IPSE program. This means that GVRA will no longer provide financial support to qualified individuals attending CTP designated schools unless the school awards the student a "recognized credential" such as a certification, diploma, or degree. This would result in many of the students currently attending these programs being no longer able to afford or eligible to attend or participate. This means that GVRA will undermine its own mission and that of WIOA by limiting the range of options available to students with intellectual and developmental disabilities.

When recognized as a CTP by the US Department of Education, IPSE programs have demonstrated rigorous program design leading to a meaningful credential in the following ways (taken from the Higher Education Opportunity Act):
1. The CTP is designed to support students with IDD who are seeking to continue academic, career and technical, and independent living instruction at an IHE to prepare for gainful employment;
2. The CTP includes an advising and curriculum structure;
3. The CTP has an institutional policy for determining whether a student enrolled in the program is making satisfactory academic progress;
4. The CTP has an educational credential offered ( e.g., degree or certificate) with identified outcome or outcomes established by the institution for all students enrolled in the program;
5. The CTP program is officially acknowledged by the Southern Association of Schools and Colleges Commission on Colleges which accredits all degree and certificate programs at IHE's in GA in which the CTP program is held.

CTP approval provides a national and regional standard of approval which supersedes the definition of both 'Recognized Credential' and' Recognized Post-Secondary Credential as defined in the proposed policy.
GCDD encourages GVRA to retract its proposed policy revisions regarding post-secondary academic and vocational training and to retain the current policy provisions at this time. We thank you for this opportunity to comment and look forward to working with you on supporting and improving the IPSE programs.


Eric Jacobson
Executive Director, GCDD

Mitzi Proffitt
GCDD Chairperson