Massachusetts

The MRC develops programs and services with the participation of providers in several forums.

1. Statewide Rehabilitation Council that meets twice annually.
2. Quarterly meetings with representatives of the Executive Committee of the Massachusetts Council of Human Service Providers.
3. Periodic district wide meetings with community rehabilitation programs.
4. Interagency and cross–disability agency councils.
5. Task specific work teams.
6. Massachusetts Association of People Supporting Employment first (MAAPSE) In partnership with MRC, CRP personnel actively participated in the process for competitive procurement, CIES, the disability employment pilot project work team and the mental health services work team. This included for the first time real pricing of community rehabilitation program services and performance reimbursement. (Page 251)

MRC and community providers collaborate in developing programs and services in such forums as: Statewide Rehabilitation Council that meets twice a year; quarterly meetings with representatives of the Executive Committee of the Massachusetts Council of Human Service Providers; periodic district wide meetings with community rehabilitation programs, interagency and cross disability agency councils; task specific work teams and the Massachusetts Association of People Supporting Employment First (MAAPSE). (Page 299)

• 6.   Research Best Practices Models to Increase Employment of Individuals with Disabilities: Based on public comments regarding innovative employment programs, MRC will research best practice models designed to increase the employment rate of individuals with disabilities in Massachusetts. MRC will find out more about the suggested models including: the practices of North Dakota, South Dakota, Alaska, and Wyoming, which have achieved increased results of 50% employment rates of individuals with disabilities; Innovative youth employment models from Georgia, Nevada, Kentucky; and the RespectAbility Disability Employment First Planning Tool, among others. (Page 302)

No specific disability related information found

• State–level coordination of youth–serving resources to drive local coordination
• Models for braiding of funds to serve populations with highest need (and traditionally underserved)
• Identification of new program models for ISY, OSY, and older youth. (Page 153)

Over the years, Massachusetts has won several Disability Employment Initiative grants and other resources through USDOL Office of Disability and Employment Policy to strengthen the system’s capacity to support individuals with disabilities. The Massachusetts Disability Employment Initiative (DEI) III Grant administered through a partnership with five Career Centers, Work without Limits, and the Institute for Community Inclusion. Grant supports programs aimed at improving employment outcomes for persons with disabilities. Of the 535 individuals who have enrolled in the program, 292 (55%) have achieved employment (2014–2015). (Page 96)

Franklin Hampshire Career Center works with a participant named “Eli”. Eli became a customer of the Career Center around January of this year, he has been working as a janitor with very limited hours, and he has maintained that job for a number of years. In interviewing Eli, he shared that he wanted a ‘career’ not just a job. He knew he wanted to go into a specific field.

The Career Center works with its partners because Eli is co–enrolled in Department of Mental health, a MRC and a member of a vocational rehabilitation Clubhouse model program. Eli enrolled in training under DEI and WIA funding. (Page 629)

The Disability Resource Coordinator from the One–Stop Career Center has presented at the staff meeting of both Mass Rehab, as well as the Department of Developmental Services. MRC has made numerous referrals to the DEI program that we have been able to assist with tuition/training and job placement. As a direct result of the Regional Meetings, we have increased awareness of the DEI Grant, as well as our Center services and have streamlined the process of inter–communication regarding clients. (Page 631)

7. CareerAccess Initiative: MRC will closely follow the CareerAccess initiative. CareerAccess is a community–driven proposed program to reform the current Social Security Administration’s Supplemental Security Income Program (SSI) rules so that young adults with disabilities can work and achieve their full potential without risking losing their disability benefits. If the proposal is adopted by the Social Security Administration, MRC will help its consumers take full advantage of the program as part of their individual plans for employment. (Page 302 & 314)

MRC passed this indicator again in FY 2014. Much effort has gone into assuring the accurate coding of the primary source of income of employed consumers both in and without the presence of other income such as SSA or other public benefits. MRC will continue to train staff in this area and validations have been added to the MRCIS case management system to avoid potential coding errors.

Standard and Indicator 2.1: Ratio of minorities served to non–minorities Actual: .94 Standard: .80 Result: PASS

MRC passed this indicator with a high score. MRC continues to make a strong commitment to achieve equality in service delivery. MRC counselors should be commended for their good work in dealing with the challenges and needs associated with diversity, and keeping it a priority. (Page 314)

Massachusetts has a number of programs for out-of-school youth that MCB works with to provide services for individual consumers. During the past year, MCB has been working closely with the Partners for Youth with Disabilities (PYD), a non-profit agency that empowers youth with disabilities to reach their full potential by providing transformative mentoring programs, youth development opportunities, and inclusion expertise. After a pilot in one region, MCB received a one-year grant of $43,000 from the National Institute on Disability and Rehabilitation Research (NIDRR) to provide the service statewide. MCB offers all transition-age students and out-of-school youth mentoring through the Partners for Youth with Disabilities Mentor Match program. The Mentor Match pairs youth and young adults with disabilities with adult mentors who best fit their personality, interests, and skills. MCB has identified and matched 34 mentors and 34 young consumers for the program. Participants in the pilot program suggested that the agency also include networking opportunities among all of the mentors and the consumers involved. In response to this suggestion, the provider has hired a mentoring events specialist and held 18 group events across the state during 2015. These events focus on topics such as goal setting, job search, stress management, and professional communication. Since the grant-funded program has been quite successful this year, MCB will fund it in future years for all interested consumers. Two MCB staff members have been invited to present a national webinar for VR professionals on this initiative. (Page 338)

The Massachusetts Commission for the Blind has always had a good relationship with MassHealth, the program that provides Medicaid services in Massachusetts. About 20% of the agency’s consumers benefit from the program. MassHealth services have been key comparable benefits that have enabled many VR consumers to reach their vocational goals. The agency‘s state-funded Deaf-Blind Extended Supports Program also works closely with MassHealth to provide services under the Home and Community-Based waiver that can provide the underpinning of vocational outcomes in some cases. (Page 347)

Follow closely the CareerAccess initiative. CareerAccess is a community-driven proposed program to reform the current Social Security Administration’s Supplemental Security Income Program (SSI) rules so that young adults with disabilities can work and achieve their full potential without risking losing their disability benefits. If the proposal is adopted by the Social Security Administration, MCB will help its consumers take full advantage of the program as part of their individual plans for employment. (Page 396)

The Commonwealth has enacted a state law to prohibit the use of cash assistance, including TAFDC, in electronic benefit transfer (EBT) transactions at liquor stores, casinos, gambling casinos or gaming establishments, and retail establishment which provides adult-oriented entertainment in which performers disrobe or perform in an unclothed state for entertainment, as well as other establishments not identified in Section 408(a)(12). Retailers face fines from $500 for a first offense, $500 to $2500 for a second offense and not less than $2500 for a third offense. See M.G.L. c. 18, § J. In addition, the Commonwealth has prohibited the use of cash assistance held on EBT cards to purchase alcoholic beverages, lottery tickets, gambling, adult oriented material or performances and other items and services (See M.G.L. c. 18, § I). Clients who violate the purchasing provisions must pay the Commonwealth back for the prohibited purchase. For a second offense, the client is disqualified from benefits for two months and must pay the Commonwealth back for the prohibited purchase. For a third offense, the client is disqualified from benefits permanently and must pay the Commonwealth back for the prohibited purchase. (Page 445)

Benefits are provided to eligible applicants and recipients on a statewide basis. The standards for determining eligibility and the amount of assistance are established on an objective and equitable basis in accordance with the Department’s regulations. These standards are based on an individual’s income, assets, family size and circumstances. All Department activities are conducted in accordance with Title VI of the Civil Rights Act of 1964, Section 504 of the Rehabilitation Act of 1973, as amended, the Americans with Disabilities Act of 1990, as amended, the Age Discrimination Act of 1975, as amended, and the Massachusetts Constitution. The Department does not discriminate on the basis of race, color, national origin, age, disability, religion, political beliefs, sexual orientation, gender, gender identity or expression, creed, ancestry or Veteran’s status in admission or access to, or treatment or employment in its programs or activities. An applicant/recipient has a right to a fair hearing as set forth in the Department’s regulations at 106 CMR 343.000, et seq. (Page 450)

Most participants reside in subsidized housing and rely on Medicare and/or Medicaid for medical insurance needs. They are looking for positions that will not result in the reduction of these important benefits. It is a well-known phenomenon frequently called the “cliff effect.” When individual relying on public assistance increase his/her earnings so they rise above the official poverty level, they then begin to lose eligibility for earned income tax credit, childcare subsidies, healthcare coverage, SNAP etc. even though they are not yet self-sufficient. Many SCSEP participants refuse higher earnings to avoid losing these public benefits. (Page 574)

c) Creation and implementation of workshops for job seekers with disabilities at One–Stop Career Centers covering specific resources, SSI and VR benefits counseling, pre– and post–employment support services offered through VR, job fairs, employer industry panels job seekers, etc. (Offered at various sites.) (Page 615)

In addition, the Commonwealth has partnered with a nonprofit, full-service credit-counseling agency, funded through a large banking institution’s nonprofit foundation, to offer financial literacy and credit counseling workshops. These workshops are available to clients at no cost, statewide, to assist in their development of short and long-term financial planning. The workshop curriculum encompasses how clients reduce or eliminate fees associated with using their EBT cards or otherwise utilize their TAFDC benefits through direct deposit or direct vendor payments for rent, utilities, etc. While clients are instructed on how to better budget their TAFDC funds, they are also reminded of the prohibited items, services and establishments, identified under State law and the associated penalties. (Page 446) 

b)  Low–Income, Low–Skilled: Many individuals who are homeless, receiving public assistance or public housing, CORI, or individuals with limited skills (LEP or lack of high school credentials etc.) face challenges that require multiple supports offered across a range of partners. The state is looking to develop curriculum for cross–training to ensure staff at multiple agencies can help an individual understand available resources, the impact of work on wages and public benefits (benefits counseling or “cliff effect” information for TANF–SNAP), and next steps to move along a career pathway. The adult education network of providers will contribute information on evidence–based models that support integrated education and training, career pathways, wrap–around/college and career readiness support services to assist staff in building supports that create positive outcomes for low–income, low–skilled populations. (Page 96)

State level policies that outline a referral process for out–of–school youth to the core programs to acquire access to literacy skills, secondary credential attainment, public benefits, and pre–employment transition services as required under WIOA will be operationalized. Local partners will also be encouraged to collaboratively leverage resources for the purposes of improving outcomes for out–of–school youth by pursuing joint applications for “sector” initiative, expanded use of federal On–the–Job Training funding, expand Adult Career Pathway model piloted in regions, “pathways” funding on specific populations and career pathways, and align programming with state workforces partners such as YouthWorks. (Page 172)

The MRC will ensure that its Area Offices will determine eligibility for vocational rehabilitation services for students with disabilities and will provide PETS based on individual need. For those students eligible for vocational rehabilitation services, the rehabilitation counselor, together with the student, will develop an IPE stating the vocational goal and the services necessary to achieve it. These services may include: vocational guidance, work evaluation, skills training at a college or community rehabilitation program, adaptive equipment, and benefits counseling. Required PETS activities are: job exploration counseling; work–based learning experiences; counseling on opportunities for enrollment in comprehensive transition or postsecondary educational programs at institutions of higher education; workplace readiness training to develop social skills and independent living; and instruction in self–advocacy. The ESE and the MRC will provide guidance for local MRC staff and school district personnel on transition planning for students with disabilities that facilitates the development and implementation of IEPs under section 614(d) of the IDEA. MRC develops IPEs for students with disabilities as soon as possible. (Page 248)

Additional Functions Performed: Incumbents perform the following: Supervise and monitor unit activities such as consumer evaluations and case maintenance to ensure effective service delivery and compliance with agency policies and standards. Establish and maintain program and unit information systems. Prepare and monitor program and/or unit budget and allocation of funds. Develop and implement policies and procedures for assigned units and programs in accordance with agency regulations and applicable laws. Determine service delivery hours and caseloads to staff consistent with agency policies and consumer needs. Assist in the development and implementation of consumer needs assessment programs. Promote agency services to ensure appropriate referrals to the Vocational Rehabilitation Division. Coordinate state and federal compliance review audits; gather sample studies, conduct in-house reviews of cases for compliance and provide requested materials, information and evaluations to ensure agency compliance with federal, state and agency policies, procedures and regulations regarding vocational rehabilitation. Coordinate Supplemental Security Income (SSI) and/or Social Security Disability Insurance (SSDI) referrals; act as office liaison on all matters related to SSI/SSDI consumers receiving benefage its from the Social Security Administration. Act as liaison regarding specific disabilities or special populations by attending meetings and providing information to counselors to ensure that the agency is reaching the specific populations, and to discuss current information on the target groups. Based on assignment, develop and negotiate contracts and grants with appropriate vendors; develop, negotiate and manage contract service budgets in order to assure program effectiveness and compliance with state and federal guidelines, policies and procedures. (Page 275)

4. The most important and needed VR services listed by consumers were job placement (89%), career counseling (84%), supported employment (80%), benefits planning (78%), ongoing supports to assist in retaining employment (74%), On–the–Job Training or Job Coaching (71%), and College Education (68%). School to work transition, obtaining a high school diploma, and college education were the most needed services by consumers of transition age. (Page 282)

WIOA and its state plan requirements have been discussed at each quarterly meeting of the Rehabilitation Council since its enactment. The agency and the council have developed new goals and priorities and plans for innovation and expansion based on the new law. MCB and the Rehabilitation Council are in full support of the Workforce Development Plan Vision: All Massachusetts residents will benefit from a seamless system of education and workforce services that supports career pathways for individuals and leads to a more informed, educated, and skilled workforce, which meets the Commonwealth‘s businesses’ demands and sustains a thriving economy. The agency and the council are committed to the following paths to the realization of that vision: (Page 333)

The Massachusetts Commission for the Blind has always had a good relationship with MassHealth, the program that provides Medicaid services in Massachusetts. About 20% of the agency’s consumers benefit from the program. MassHealth services have been key comparable benefits that have enabled many VR consumers to reach their vocational goals. The agency‘s state-funded Deaf-Blind Extended Supports Program also works closely with MassHealth to provide services under the Home and Community-Based waiver that can provide the underpinning of vocational outcomes in some cases. (Page 347)

As stated in a previous section: The Massachusetts Department of Developmental Services (DDS) and the Massachusetts Department of Mental Health (DMH) have over the years worked cooperatively with MCB and provided extended services to a number of legally blind persons that have been provided supported employment services by MCB. During 2015 and 2016, MCB has collaborated with the DDS on plans to expand services to mutual consumers that includes an initiative to better identify consumers who could benefit from supported employment services and are not receiving them at this time. A new Memorandum of Agreement that includes provisions for use of joint agency resources to ensure quality service delivery and long term supports for supported employment was executed in November, 2015. This includes a formal commitment of funding from MCB for appropriate supported employment services and a commitment from DDS for funding of the long-term, ongoing employment support services when needed. The agreement also provides for cross-training of staff. (Page 401)

In addition, as also stated in previous sections: The Massachusetts Department of Developmental Services (DDS) and the Massachusetts Department of Mental Health (DMH) have over the years worked cooperatively with MCB and provided extended services to a number of legally blind persons that have been provided supported employment services by MCB. During 2015 and 2016, MCB has collaborated with the DDS on plans to expand services to mutual consumers that includes an initiative to better identify consumers who could benefit from supported employment services and are not receiving them at this time. A new Memorandum of Agreement that includes provisions for use of joint agency resources to ensure quality service delivery and long term supports for supported employment was executed in November, 2015. (Page 419)

The provisions of Section 408(a)(12) of the Social Security Act require States to maintain policies and practices as necessary to prevent assistance provided under the State program funded under this part from being used in any electronic benefit transfer transaction in any liquor store; any casino, gambling casino, or gaming establishment; or any retail establishment which provides adult-oriented entertainment in which performers disrobe or perform in an unclothed state for entertainment. (Page 445)

Most participants reside in subsidized housing and rely on Medicare and/or Medicaid for medical insurance needs. They are looking for positions that will not result in the reduction of these important benefits. It is a well-known phenomenon frequently called the “cliff effect.” When individual relying on public assistance increase his/her earnings so they rise above the official poverty level, they then begin to lose eligibility for earned income tax credit, childcare subsidies, healthcare coverage, SNAP etc. even though they are not yet self-sufficient. Many SCSEP participants refuse higher earnings to avoid losing these public benefits. (Page 574)

c)  Creation and implementation of workshops for job seekers with disabilities at One–Stop Career Centers covering specific resources, SSI and VR benefits counseling, pre– and post–employment support services offered through VR, job fairs, employer industry panels job seekers, etc. (Offered at various sites.) (Page 615)

20. Specialized Service Centers: A specialized service center of a core partner is defined as a local service center providing specialized services to shared customers such as assistive technology, benefits counseling, and vocational counseling. (Page 626)

1. Continue to provide soft skill training to consumers: Soft skills training for VR staff has been completed by MRC Training Department. In addition, all area offices offer training in soft skills to all consumers, including transition aged individuals through job clubs and stand– alone programs open for all disability groups. Training is delivered using PowerPoint and includes opportunities to role play. Soft–skills training has been offered at the 2014 Consumer Conference as a stand–alone workshop and with a resume workshop at the 2015 Consumer Conference. Soft skill trainings have been offered in high schools to assist in the transition process from school to work. (Page 237)

4. The most important and needed VR services listed by consumers were job placement (89%), career counseling (84%), supported employment (80%), benefits planning (78%), ongoing supports to assist in retaining employment (74%), On–the–Job Training or Job Coaching (71%), and College Education (68%). School to work transition, obtaining a high school diploma, and college education were the most needed services by consumers of transition age.

5. The most important job characteristics that MRC consumers indicated they are looking for in a job include a friendly job environment (95%), job satisfaction and personal interests (95%), earning a living wage (94%), an adequate number of hours worked per week (94%), vacation and other leave benefits (89%), and promotional opportunities (88%). (Page 282)

Report of Progress: The development of increased training opportunities for transition-age consumers who are not going to college continues to be a major focus area. During FFY 2015, MCB worked with Project SEARCH, an initiative that began in Cincinnati, Ohio to develop a program tailored for MCB consumers in Massachusetts. Project Search is a nine-month school-to-work program that takes place entirely at the workplace. MCB has chosen two providers: the Carroll Center for the Blind and the Polus Center for Social and Economic Development. The agency was able to recruit two large hospitals as worksites. Nine MCB consumers just completed working at the work sites with the goal of identifying career objectives and gaining work experience. There was a job coach at each work site to provide hands-on training and support to the participants. Project Search has had a 70% job placement rate in its programs in Ohio and other states. At least five participants have been hired, although some are still per diems. MCB intends to continue to expand Project Search to meet the needs of consumers who choose to participate in this kind of program. A new program is beginning this spring at the same worksites. MCB will consider other types of worksites such as hotels in the future if there is consumer interest. (Page 414)

Specific innovation and expansion (I&E) activities and initiatives include:  The development of increased training opportunities for transition-age consumers who are not going to college continues to be a major focus area. During FFY 2015, MCB worked with Project SEARCH, an initiative that began in Cincinnati, Ohio to develop a program tailored for MCB consumers in Massachusetts. Project Search is a nine-month school-to-work program that takes place entirely at the workplace. MCB has chosen two providers: the Carroll Center for the Blind and the Polus Center for Social and Economic Development. The agency was able to recruit two large hospitals as worksites. Nine MCB consumers just completed working at the work sites with the goal of identifying career objectives and gaining work experience. There was a job coach at each work site to provide hands-on training and support to the participants. Project Search has had a 70% job placement rate in its programs in Ohio and other states. (Page 420)

The September forum was sponsored by SRC–General, SRC–Blind and the Department of Education. A panel discussed the federal and state initiatives designed to increase employability for students with disabilities, and how to maximize the positive impact of pre–employment transition services through effective collaboration. (Page 203)

All Massachusetts residents, including individuals with disabilities, will benefit from a seamless system of education and workforce services that supports career pathways for individuals and leads to a more informed, educated, and skilled workforce, which meets the Commonwealth‘s businesses‘ demands and sustains a thriving economy. To achieve this vision, Massachusetts will engage businesses to understand their needs and develop an integrated education and workforce system that supports career pathways to prepare residents with foundation, technical, professional skills and information and connections to postsecondary education and training. MRC will work with its core workforce partners to: 

1. Design career pathways across partners aligned with business demand
2. Improve foundation skills and transition to postsecondary education and training for individuals with barriers to employment
3. Assist individuals to achieve economic self–sufficiency through support services, labor–market driven credentialing, and employment
4. Meet the needs of job seekers and businesses who engage in the public workforce system (including partner programs) (Page 300)

The majority of MA-SCSEP participants seeks and obtains entry-level part-time jobs with a flexible schedule. Therefore, realistic expectations for this population is in creating career pathways that will enable these individuals to obtain entry-level positions and perhaps to move into higher skilled occupations with time. It is expected that entry-level positions in the service sector such as Home Care and Food Service will offer the most suitable jobs for MA-SCSEP participants. (Page 573)

In order to implement the elements of a career pathway model in the region that require shared program design, service delivery, staffing or infrastructure costs, local areas could consider the following areas for shared resources to:

a) Leverage resources collaboratively for the purpose of expanding access to credentials and work–based learning for low–skilled individuals (local partners can pursue joint applications for “sector” initiatives such as the Workforce Competitiveness Trust Fund or Workforce Training Fund, expanded use of federal On–the–Job Training funding, expand the ABE Career Pathway models piloted in regions, “pathways” funding on specific populations and career pathways, etc.)

b) Align and map out the supports for individuals from different programs along a career pathway to support long–term, credential attainment. (Page 614)

Section identified but no detailed information specifically addressing disability or implementation.  (Page 329)

Data Collection and Reporting Systems for Core WIOA programs The primary workforce development programs are administered by the Department of Career Services (DCS) within the Executive Office of Labor and Workforce Development (EOLWD) and operate through the State’s network of One–Stop Career Centers. DCS manages the Massachusetts One–Stop Employment System (MOSES) –– a client/server application and database that serves as the unified management information, client tracking, case management and reporting system used by staff at career centers and other workforce development service providers in Massachusetts. The application is distributed through a Citrix interface providing users with flexibility for data entry and report access. MOSES collects information and tracks data through the MOSES database for the following programs: 

• Title I Adult
• Trade Adjustment Assistance (TAA)
• National Dislocated Worker Grants (formerly NEGs)
• Title I Dislocated Worker (inc. Rapid Response)
• Jobs for Veterans State Grant (JVSG)
• Disability Employment Initiative Grants (DEI)
• Title I Youth  (Page 110)

A system for tracking the services provided to individuals jointly eligible for MRC and DDS services will be developed and implemented in order to assess the referrals, outcomes, impact and effectiveness of services provided to individuals who receive services as part of this MOA. Each MRC and DDS Area Office will be required to provide documentation on a regular basis.

This Memorandum of Agreement will be reviewed annually by the leadership of both agencies to identify areas for clarification, improvement, or additions to further promote collaboration and successful employment of individuals with intellectual disabilities. (Page 261)

The Rehabilitation Council (MCB RC) has continued to review the consumer satisfaction studies conducted annually on a routine basis. The Council had in previous years provided input into the design of these studies as well as the design of the comprehensive needs assessment study. The data collection for the latest comprehensive needs assessment study was completed before the new requirements for inclusion of need for pre-employment transition services were added. The MCB RC agreed with the agency‘s proposal for a separate needs assessment survey to be sent out for parents to fill out for this population (age 14-22) about their educational services, pre-employment transition services, transition services and vocational services. The MCB RC will work with the agency to develop a new comprehensive needs assessment methodology in line with the requirements and focus of WIOA on competitive integrated employment for the next scheduled comprehensive needs assessment (2017). (Page 333)

2% of the respondents were under age 18 and 1% aged 18-25. Their reported needs did not differ significantly from the other respondents. However, Congress, RSA, and MCB have clearly identified youth as an underserved group in light of their needs for pre-employment transition services and transition services. The data collection for the latest comprehensive needs assessment study was completed before the new requirements for inclusion of need for pre-employment transition services were added. The MCB SRC agreed with the agency‘s proposal for a separate needs assessment survey that has been sent out for parents to fill out for this population (age 14-22) about their educational services and pre-employment transition services, transition services and vocational services. The analysis of this needs assessment survey will be integrated with the comprehensive needs assessment. In addition, a similar needs assessment survey is being conducted with Teachers of the Visually Impaired. Preliminary analysis of these two surveys indicates that there is a clear need for pre-employment transition services. (Page 379)

The data collection for the latest comprehensive needs assessment study was completed before the new requirements for inclusion of need for pre-employment transition services were added. The MCB SRC agreed with the agency‘s proposal for a separate needs assessment survey that has been sent out for parents to fill out for this population (age 14-22) about their educational services and pre-employment transition services, transition services and vocational services. The analysis of this needs assessment survey will be integrated with the comprehensive needs assessment. In addition, a similar needs assessment survey is being conducted with Teachers of the Visually Impaired. Preliminary analysis of these two surveys indicates that there is a clear need for pre-employment transition services. (Page 393)

WIOA NPRM at 20 CFR §678.800 requires that the state’s network of One–Stop Career Centers be certified by the Local Boards. WIOA further mandates that the State Board, in consultation with chief elected officials and Local Boards must establish objective criteria and procedures that Local Boards must use when certifying career centers. These new career center standards will further and be consistent with the Governor’s and State Board’s guidelines, guidance and vision. The new criteria will evaluate the one–stop career center delivery system for effectiveness in addressing business and job seeker needs in the enhanced Massachusetts demand–driven workforce delivery system. The new criteria will also ensure compliance with WIOA Section 188 nondiscrimination provisions and the Americans with Disabilities Act. In order to create and implement the One–Stop Certification process and policy under WIOA, the Massachusetts State Board created the Career Center Standards and Process Workgroup (CCS&P). The CCS&P Workgroup is comprised of a statewide diverse group of workforce professionals, representatives of core and other partner programs, including Vocational Rehabilitation, representatives of targeted customer groups, and business representatives. The group is in the process of rolling out Massachusetts’ inaugural statewide career center standards in the areas of cost effectiveness, integrated services, accessibility, effective leadership, performance and responsiveness to the demand driven model. Accessibility standards include the examination of systems to ensure staff knowledge of and compliance with Section 188 of WIOA. The standards exceed WIOA mandates and will become a core driver of change through the WIOA–mandated career center operator competitive selection process. (Page 142)

Every One–Stop Career Center in Massachusetts is currently fully accessible and in compliance with WIA Section 188 regulations on non–discrimination. As stated above, the certification process for One–Stop Career Centers and the state guidelines for local WIOA plan submissions both address matters pertaining to physical and programmatic accessibility. The Massachusetts DCS Field Management and Oversight unit conducts on–site monitoring at all 32 One–Stop locations, using the set of One–Stop Career Center Quality Assurance Standards. Further, the Massachusetts Department of Capital Asset Management (DCAM) conducts an accessibility review for any new leases or lease renewal activities based on ADA guidelines. Policy dictates that if any deficiencies are identified that One–Stops are informed in writing of the findings and given a deadline for when corrections need to be completed. There are no outstanding issues currently. (Page 143)