Creating Change with Incremental Steps: Enhancing Opportunities for Early Work Experience: Report

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Creating Change with Incremental Steps:
Enhancing Opportunities for Early Work Experience
Authors:
Michael Morris
Nanette Goodman
Burton Blatt Institute at Syracuse University
January 28, 2013
This project was funded by the U.S. Department of Education, National Institute on Disability and
Rehabilitation Research’s Employment Policy and Measurement Rehabilitation Research and Training
Center, under cooperative agreement H133B100030. The findings and conclusions are those of the authors
and do not represent the policy of the Department of Education. The authors retain sole responsibility for
any errors or omissions.

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Introduction ............................................................................................................................... 4
Background ................................................................................................................................. 4
1. Empirical evidence ........................................................................................................... 7
2. Review of programs and legislation that can facilitate work experience . 11
a. Transition Planning in the Individuals with Disabilities Education Act ............. 13
i. Description ............................................................................................................................................. 13
ii. Monitoring ............................................................................................................................................ 13
iii. History ................................................................................................................................................... 15
b. Vocational Rehabilitation..................................................................................................... 16
i. Description ............................................................................................................................................. 16
ii. Monitoring ............................................................................................................................................ 16
iii. History ................................................................................................................................................... 17
c. Career and Technical Education ......................................................................................... 19
i. Description ............................................................................................................................................. 19
ii. Monitoring ............................................................................................................................................ 20
iii. History ................................................................................................................................................... 20
d. Employment and Training Programs/Workforce Investment Act ....................... 21
iv. Monitoring ........................................................................................................................................... 22
v. History .................................................................................................................................................... 22
3. Availability and Use of Work Experience .............................................................. 23
4. Barriers to Effective Programs ................................................................................. 26
a. Schools and IDEA transition planning ............................................................................. 26
b. Vocational Rehabilitation..................................................................................................... 27
c. Career and Technical Education ......................................................................................... 29
d. Employment and Training Programs/Workforce Investment Act ....................... 29
e. Interaction with Social Security Programs .................................................................... 30
5. Recommendations ........................................................................................................ 31
References ................................................................................................................................ 34

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Creating Change with Incremental Steps
Enhancing Opportunities for Early Work Experiences
Introduction
In a post Americans with Disabilities Act (ADA) era, federal policies and government
infrastructure have yet to be aligned to produce enhanced employment and economic
status for millions of working age adults with disabilities. The fragmentation of service
delivery systems and the complexity of well-intentioned work incentives for Social
Security beneficiaries have been well-documented. Transformative ideas to reframe the
relationship of government support, employers, service delivery systems, and youth and
adults with significant disabilities require large scale demonstrations over an extended
period of time to yield sufficient evidence to guide and inform policy reform.
In the interim, there are significant opportunities to create meaningful, sustainable change
through more incremental steps that build on available evidence to shape policy
development and improve guidance to the field on existing policy that can have
meaningful impact on individual employment and economic results and systems
alignment. This five-part series on “Creating Change with Incremental Steps” is not
intended to displace larger policy frameworks for testing of big ideas. However, each of
these defined change approaches will keep moving the public and private sectors forward
to the benefit of the choices and interests of youth and adults with disabilities to be more
productive, independent, and economically self-sufficient. This first paper offers the
evidence for enhancing opportunities for early work experiences for youth with
disabilities and the recommended policy changes and guidance to accelerate adoption of
best practices.
Background
Youth with disabilities are much less likely to be employed as their non-disabled
counterparts. In May 2012, the Bureau of Labor Statistics reported that their employment
rate during the years following high school (ages 20-24) is 34 percent compared with 62
percent for youth without disabilities (US Department of Labor, 2012a) and this disparity
continues through adulthood.
Getting youth with disabilities into the labor force early is a key determinant of the entire
trajectory of their working lives. Research over the past 30 years has shown that youth
with disabilities who have paid work experiences during their secondary school years are
more likely to be successfully employed after they leave school than those without such
work experience. This research has become the basis for several respected organizations

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(National Association of Special Education Teachers, National Collaborative on
Workforce and Disability for Youth) to include hands-on work as an essential element for
preparing youth with disabilities for post-school employment.
Work experience while in secondary school increases youth’s motivation to work toward
a career, provides a greater understanding of the skills needed to succeed at job tasks and
work with supervisors and coworkers, and gives the student a better knowledge of career
options and a greater understanding of disability related work accommodation strategies
(Burgstahler & Bellman, 2009). In addition, work experiences can raise the work-related
aspirations of youth and their families, and demonstrate to employers and community
members the value that adolescents with severe disabilities can make to the workforce
(Carter et al., 2010).
In fact, the benefits of early work experience are not limited to adolescents with
disabilities. Researchers across disciplines, including psychologists, sociologists, and
economists, have found that the combination of work and schooling in adolescence can
help develop independence, a sense of responsibility, and time-management and other
skills useful for the transition to adulthood. However, studies of youth in general
(regardless of disability status) have shown that work is not without risk. Teens who
work long hours tend to have lower grades, are more likely to be absent from school and
are more likely to drop out than teens who work fewer hours. In addition, as hours of
work increase, adolescents drink and smoke more, and engage in a wide range of problem
behaviors (Mortimer, 2010).
Working while in high school has become less common over the past ten years even for
students without disabilities. Statistics from the Bureau of Labor Statistics (US
Department of Labor, 2012b) indicate that the employment rate of teenagers ages 16-19
has dropped from 39.6 percent in 2002 to 25.8 percent in 2011. Summer jobs have also
been on a downward trend. The percent of teens employed over the summer fell from 52
percent in the summer of 2000 to 33 percent in the summer of 2009. This trend is visible
across all demographic groups by age, sex and race (Morisi, 2010). The decline is caused
by several factors including three that are particularly relevant for discussing the
employment prospects for students with disabilities: (1) Two recessions in the past ten
years has meant that the types of jobs that teens would normally fill have become scarcer
in part because of increased competition for such jobs from adults; (2) The number of
federally funded summer jobs has diminished; (3) Increasing academic achievement
required for graduation is limiting the time available for non-academic pursuits and
increasing the number of students who are spending part of their summer in school
(Morisi, 2010).
It is important to distinguish “work” from “work-related experiences”—a term used by
schools and surveys that may include short-term career exploration opportunities such as
workplace visits, short-term volunteering, or job shadowing in addition to hands-on work
experience. Although research consistently finds positive impacts from hands-on work,
research has found mixed results of whether these other opportunities increase post-

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school employment rates (Hasazi, 1985; Shandra & Hogan, 2008; Carter et al., 2011a).
Some research places an emphasis on “quality jobs” while others focus on any job. The
empirical research supporting the relationship between working while in secondary
school and success in the adult labor market does not distinguish whether the high school
jobs are consistent with the student’s long-term interests and career goals. “Even jobs that
do not offer entry points into specific careers or align with their long-term interests can
still provide an opportunity for the youth to learn basic skills and work habits applicable
in future occupations, discover career-related preferences and interests, navigate
interpersonal relationships more effectively, learn through encountering natural
contingencies (both positive and negative), and develop greater self-determination.”
(Carter et al., 2011b)
Many youth find part-time and summer jobs on their own, with help from friends or
through family networks. Youth with disabilities face a number of barriers that make
these avenues less productive and as a result these youth may need more assistance from
government programs.
Several systems are in place to help high school students with disabilities achieve
employment goals, including programs authorized by the Individuals with Disabilities
Education Act, the Vocational Rehabilitation Act, the Perkins Vocational and Applied
Technology Act and the Workforce Investment Act.
Unfortunately, these systems are only partially meeting the goal of serving all high school
students who could benefit from assistance. Although the programs are encouraged to
provide the needed support, none are mandated. Gaps in the system, overlapping
responsibilities, and weak interagency agreements compound the problem. Some youth
receive excellent services and support from small, targeted programs such as the Marriott
Bridge program, Project Search and others. However, the system lacks a coherent vision
on how best to help youth on a larger scale gain work experience during their high school
years. The Individuals with Disabilities Education Act mandates that schools identify the
skills, experiences and services that students need to transition from school to work. This
could include high school work experience but that entails drawing upon other programs
designed for that purpose, which may either not exist or not be easily accessed. Schools
cannot serve this purpose by themselves as it is not their core competency and they
generally do not have direct ties to employers. While career and technical education
programs provide services, they do not focus on linking up with community jobs. At the
same time, vocational rehabilitation programs kick in too late to assist students obtain
jobs prior to graduation. The major federal program aimed at assisting at-risk youth—the
Workforce Investment Act--accepts youth with disabilities, but there are no systematic
mechanisms to promote their inclusion.
Revamping the system would take a major piece of legislation, but this paper points out
some short-term steps that can be taken to increase the ability of these programs to
facilitate work experience. We focus on two types of modifications including (1)

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changes to enabling legislation and federal regulations and (2) changes to reporting and
monitoring requirements. This paper is structured as follows:
Section 1 describes the empirical evidence that establishes that students with disabilities
that gain work experience while in high school have more successful work outcomes as
adults.
Section 2 reviews the federal laws and policies that are in place to facilitate work
experience. This section includes a description of the laws and regulations with a focus
on the specific components that address high school work experience, how the programs
are monitored and a short history of the law.
Section 3 presents data on the extent to which students with disabilities work while in
high school. The data shows that while students with disabilities overall are equally
likely to work as students without disabilities, students with more significant disabilities
are much less likely to work.
Section 4 describes potential reasons why current federal laws are not effective in
facilitating work experiences for students with disabilities.
Section 5 presents recommendations for strengthening the effectiveness of federal
legislation.
1. Empirical evidence
Studies conducted over the past 25 years provide empirical evidence that suggests that
students with disabilities who have paid work experience while in school have higher
rates of sustainable employment than students with disabilities who do not have work
experience.
Determining the effectiveness of paid work experience, however, is a complicated task
that must take into account the issue of self-selection. Students who obtained
employment had the motivation to work, and probably had higher expectations, more
encouraging parents, better social networks, fewer functional difficulties, and/or better
work-related skills. A simple comparison of youths who had paid experiences while still
in school with those who did not does not account for these differences, and thus may
overestimate the impact of early work experience.
A multivariate analysis that attempts to capture some of these attributes may lessen this
bias somewhat, but cannot eliminate it. While it is possible in a multivariate analysis to
control for some of these characteristics such as severity of disability or availability of
certain supports, other characteristics, such as motivation, are more difficult to quantify
and capture. As a result, these studies show a strong correlation between secondary-
school work experience and longer-term employment success but they do not show

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causation. There will always be unobservable characteristics that will be associated both
with the likelihood of obtaining employment while in school and the likelihood of
obtaining employment later in life, independent of any impact of work experience prior to
graduation.
A recent demonstration project conducted by the Social Security Administration may
provide evidence for the causal link between employment during school and employment
after graduation that addresses this methodological issue. The demonstration was a
random assignment design. Youth who are SSA beneficiaries or at risk of becoming SSA
beneficiaries were randomly assigned to receive either Youth Transition Demonstration
(YTD) services or only non-YTD services generally available in the community. In other
words, selection into the program was independent of characteristics that might be
associated with employment.
YTD services included benefits counseling, job development, job placement, career
counseling., and services to support employment. In addition, SSA waived certain SSI
and SSDI program rules to provide incentives for youth with disabilities to initiate work
or increase their work activity. Ten YTD projects were implemented across the country.
Preliminary findings suggest that the projects that focused on employment and provided
an intense level of service were able to significantly increase the probability that
participants would be employed after high school (Fraker et al. 2013). This random-
design demonstration assessed the impact of a combination of services and supports
rather than a single service.
The studies most often cited as evidence of the benefits of work experience while in
school and long-term employment are presented below in the order of their publication.
They support the correlation between the two types of work, but as they do not have a
randomized design, the studies thus cannot specifically attribute later work outcomes to
earlier work experience.
1. Based on a sample of 459 youths from Vermont who exited high school between
1979 and 1983, Hasazi et al. (1985) found that students who had held paid part-
time or summer jobs were more likely to be employed following high school than
those who had not. Rather than employing a multivariate analysis, the researchers
created subsets of the data based on gender, level of functioning and geographic
location (urban/rural/metropolitan) and analyzed the bivariate relationship
between high school job experience and post-school employment for each of the
subsets. Of the students who held part-time jobs during high school, 70% were
employed at the time of the interview compared with 41% of those not holding
such jobs. Of the students who had no summer jobs, only 37% were employed
compared with 46% for those who had subsidized summer jobs and 69% of those
who had nonsubsidized jobs. Both these patterns were significantly replicated
across the subsets of respondents. Students who participated in “work
experience” programs most often associated with special class programs were no
more likely to be employed than those students who had not participated in these

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programs
2. Wagner et al. (1993) analyzed a sample of youth with disabilities from the
National Longitudinal Transition Survey (NLTS) who were enrolled in school in
1987 and were out of school (graduated, dropped out or aged out) by 1990. The
researchers developed a multivariate model to predict the likelihood of being
competitively employed in 1990. The model included vocational education,
working while in school, and a variety of other variables that could affect the
outcome including: disability category, severity (self-care skills, functional
mental skills), gender, household characteristics, race, attended a special school,
was a vocational concentrator, took vocational survey courses, took college
preparatory classes, percentage of class time in regular education, dropped out,
frequency of seeing friends outside of school, belonged to a group in high school,
percentage of student body in poverty, parent expectations
The study found that students who took vocational courses were significantly
more likely to be competitively employed regardless of whether they took only a
small number of survey vocational courses or whether they took a large number
of related courses (a concentration). This finding is suspect given that almost all
students in the study took some vocational courses (62% of students with
disabilities took vocational survey courses and an additional 35% had a
concentration in vocational and technical education) which means the students
who did not take any courses were particularly unusual and may account for their
lack of employment later on.
Although 39% of respondents had work experience while in high school, the
study found that this experience did not increase the probability of longer term
employment for youth with disabilities overall. However, it did have a significant
impact for two disability groups. Working while in school increased the
probability of employment for youth with physical disabilities by 33 percentage
points and youth with mild disabilities by 10 percentage points.
3. Benz, Yovanoff & Doren (1997) analyzed a sample of 218 students with
disabilities from Oregon and Nevada and 109 students without disabilities from
Nevada to determine the effects of school-to-work programs. In a multinomial
logit model, which included disability status, gender, social skills, vocational
needs and job search skills, having at least two work experiences (e.g. community
service, job shadowing, school based enterprise, youth apprenticeship or paid
work experience) significantly increased the odds (odds ratio=2.03) of being
competitively employed one year after high school. One problem with this study
is that it only had children without disabilities from Nevada. The differences
between the outcomes between children with and without disabilities in the study
may be distorted by differences that exist in the two states’ job markets and
economies.

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4. Benz, Lindtrom & Yovanoff (2000) analyzed the experiences of 709 participants
in Oregon’s Youth Transition Program (YTP) in the mid-1990s. Although youth
participating in the YTP are representative of all secondary youth with disabilities
with respect to primary disabling condition, students typically are referred to the
program by school staff because of additional barriers to secondary completion
and transition success. The researchers developed a multivariate model to predict
whether students would be engaging in a productive activity (e.g. work or post-
secondary education) at the time they exited the program. The independent
variables included a number of personal and demographic characteristics,
disability characteristics and needs and program services. The study found that
holding two or more jobs while in the program significantly nearly doubled a
student’s likelihood of engaging in a productive activity.
5. Rabren, Dunn & Chambers (2002) examined the employment status of 1,393
former special education students who had exited from Alabama’s schools
between 1996-2000. The post-school survey was administered approximately a
year after the students exited high school. Based on a logit model that included
gender, race, disability type, graduation status, having a job at the time of school
exit, or whether they were helped by VR, Mental Health, or another
developmental disability agency, the study found that the odds of having a job one
year after high school were 3.8 times greater for those who had paying jobs at the
time they exited high school as compared to those who did not have a job at the
end of school. The researchers did not report whether the survey instrument
asked about jobs the student held earlier in high school and if these jobs affected
the post-school employment status. Rather, it focused on whether the student had
a job at the time they exited school.
6. Baer et al. (2003) surveyed 140 randomly selected former special education
students who graduated (drop-outs were not included) from four Ohio school
districts between 1997-2000. Three student-related and three program-related
variables were used in the final logistic regression model to “produce the highest
level of prediction with the fewest variables: (a) years out of high school, (b)
having a learning disability, (c) being from a suburban school setting, (d) work
study participation, (e) vocational education, and (f) regular academics.” Work
Study and vocational education both significantly increased the odds of post-
secondary full-time employment (odds ratio 2.6 and 2.7 respectively). Because
the researchers designed the model to maximize the predictive value with the
fewest possible variables rather than to analyze the contribution of relevant
variables holding constant any variables that might be correlated with both the
relevant variable and the outcome variable, the findings have questionable
validity. In addition, the survey included a question about working while were in
high school. However, this variable was dropped from the final model ostensibly
because it did not provide additional predictive value.
7. Shandra & Hogan (2008) analyzed the effects of student’s participation in school-

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to-work programs on employment outcomes (full-time work, annual income,
employer-offered health insurance and receipt of paid sick days) using a sample
of youth with disabilities from the National Longitudinal Survey of Youth (NLSY
1997). After controlling for a number of individual characteristics (sex, race
poverty level, high school degree, post secondary education and severity of
disability), they found that respondents who had participated in any school-to-
work activities (job shadowing, mentoring, cooperative education, school
sponsored enterprise, technical preparation, internships or apprenticeships, or
enrollment in a career major) were 1.2 times more likely to be employed than
those who did not participate. They found that among the different school-to work
activities, cooperative education, which combines academic and vocational
studies with a job in a related field, is the most consistently related to
employment. Results indicate that participation in cooperative education is
positively and significantly associated with annual income, full-time work,
holding a job with employer-offered health insurance, and the receipt of paid sick
days.
8. Carter, Austin and Trainor (2011a) used the NLTS-2 to analyze students with
severe disabilities only. Respondents were considered to have a severe disability
if they had an intellectual disability, multiple disabilities or autism and were
eligible for an alternative assessment or the parent reported a functional cognitive
skill deficit in at least two areas. They developed a multivariate model that
included demographic factors, student skills, family expectations, prior work
experience and others to predict the likelihood of the student being employed two
years after high school. The study found that having paid work during school
significantly increased the odds of the student being employed after high school
(odds ratio of 2.41). Both paid school-sponsored work and paid community work
were associated this early post-school employment. However, unpaid school-
sponsored work was not associated with this outcome.
2. Review of programs and legislation that can facilitate work
experience
Several federal programs and pieces of legislation direct states and school districts to
provide employment-related services for students with disabilities. These include
programs available only to people with disabilities, such as the federal-state funded
vocational rehabilitation system, as well as programs available to students regardless of
their disability status, such as vocational educational programs and programs operated
through the Department of Labor’s one-stop system.
In addition, most secondary school students with disabilities qualify for services under
the Individuals with Disabilities Education Act (IDEA). The Act covers all school-aged
children with certain qualifying conditions (i.e., autism, specific learning disabilities,

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speech or language impairments, emotional disturbance, traumatic brain injury, visual
impairment, hearing impairment, and other health impairments) and whose disability
adversely affects their educational performance. The Act includes specific requirements
for transition planning designed to identify and coordinate needed services from all
available resources. As shown in Table 1, more than half of the transition age students
covered under IDEA have learning disabilities.
Table 1: Number of Students Ages 16-21 Served under IDEA,
by Disability Category
Disability category
All disabilities
1,273,677
Specific learning disabilities
52%
Mental retardation
13%
Other health impairments
12%
Emotional disturbance
10%
Autism
5%
Multiple disabilities
3%
Speech or language impairments
3%
Hearing impairments
1%
Orthopedic impairments
1%
Traumatic brain injury
1%
Visual impairments
<1%
Deaf-blindness
<1%
Source: Author’s computation based on data from U.S. Department of Education, Office of Special
Education Programs, Data Analysis System (DANS), OMB #1820-0043: "Children with Disabilities
Receiving Special Education Under Part B of the Individuals with Disabilities Education Act," 2009. Data
updated as of July 15, 2010. Percentages sum to slightly over 100% due to rounding.
Research often identifies “students with disabilities” as those who qualify for IDEA.
This definition includes students who may not be considered “disabled” based on other
definitions of disability such as those used in surveys or for SSA program eligibility.
In addition, some students with disabilities—those who may need accommodations but
do not need specialized instruction or other special education services-- do not qualify for
IDEA, such as students with chronic illness, epilepsy and ADHD. These students are
entitled to a free and appropriate education under the broader definition of disability in
the Section 504 of the Rehabilitation Act, which prohibits discrimination on the basis of
disability. Schools are required to develop “504 plans” for these students, but unlike
students covered under IDEA, students with 504 plans are not entitled to transition
planning services.
The number of students covered under IDEA dwarfs the number of students with Section
504 plans. Almost 6 million elementary and high school students qualify for IDEA
compared with 433,000 with 504 plans (Data Accountability Center, 2010; Shah, 2012).
While it is important to recognize that not all students with disabilities are covered by
IDEA, the vast majority of students with disabilities are covered, making IDEA a

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valuable vehicle to affect change. Also, those not covered presumably are relatively
better equipped to find employment on their own as their disabling condition is not seen
to be as significant.
a. Transition Planning in the Individuals with Disabilities
Education Act
i. Description
The Individuals with Disabilities Education Act (IDEA) mandates that each eligible child
have an Individual Education Plan (IEP). During the annual IEP development process a
team of stakeholders, which generally includes teachers, parents, school administrators,
related services personnel, and students (when appropriate), work together to develop
goals and identify the resources needed to achieve those goals.
The law requires that starting at age 16 (or younger if determined by the IEP team) the
IEP must include transition goals that describe what each student would like to do when
they exit high school and a plan to achieve these goals. The goals are supposed to be
based on the student’s strengths, preferences and interests (34 CFR 300.43(a)(2)). The
transition plan is a “statement of needed transition services for the student including, if
appropriate, a statement of the interagency responsibilities and any needed linkages.” (34
CFR 300. 347(b)(2)).
The IEP team can draw from any available resource in or outside the school system to
meet the student’s transition goals. This includes programs available to all students such
as vocational education and Department of Labor programs, as well as programs targeted
only to students with disabilities, such as vocational rehabilitation. The IEP must specify
the role that each outside entity will play, but if the outside entity does not provide the
service it is ultimately the responsibility of the school and the IEP team to ensure that the
transition goal is met (20 USC 1414(d)(6)).
The current iteration of IDEA (2004) aligns with the No Child Left Behind Act (NCLB)
in its emphasis on academic achievement and accountability measures. The Act specifies
that transition planning be “results oriented” and focused on improving academic and
functional achievement to facilitate the students transition to post-school activities
including employment.
ii. Monitoring
IDEA requires states to monitor the local education authorities and submit a State
Performance Plan (SPP) to the public and to the Department of Education (20 U.S.C.
1416(a)(3)(B); . 20 U.S.C. § 1416(b)(1)(A) (2006); 34 C.F.R. § 300.601(a) (2012)).
The Department of Education requires that all states report on 20 indicators including two
that are particularly relevant for measuring the strength of transition planning:

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 Indicator 13: “Percent of youth with IEPs aged 16 and above with an IEP that
includes appropriate measurable postsecondary goals that are annually
updated and based upon an age appropriate transition assessment, transition
services, including courses of study, that will reasonably enable the student to
meet those postsecondary goals, and annual IEP goals related to the student’s
transition services needs. There also must be evidence that the student was
invited to the IEP Team meeting where transition services are to be discussed
and evidence that, if appropriate, a representative of any participating agency
was invited to the IEP Team meeting with the prior consent of the parent or
student who has reached the age of majority” (US Department of
Education,2012).
 Indicator 14: “Percent of youth who had individualized education programs
(IEPs), are no longer in secondary school and who have been competitively
employed, enrolled in some type of postsecondary school, or both, within one
year of leaving high school” (US Department of Education, 2012).
In order to measure performance on Indicator 13, states have an option of creating a
checklist or using one created by the National Secondary Transition Technical Assistance
Center (NSTTAC). In 2009-2010, three-quarters of the states used the NSTTAC
checklist, which includes nine questions about content and process of developing the IEP.
Among other things, the checklist specifies that in order for a transition plan to meet the
indicator 13 standard, the plan must include postsecondary goals in training and/or
education and employment. And, for each postsecondary goal, the plan must identify a
transition service such as instruction, related service or community experience that will
enable the student to meet the postsecondary goal (NSTTAC, 2009).
Thus, while the indicator itself refers “transition services, including courses of study, that
will reasonably enable the student to meet those postsecondary goals,” the checklist does
not include specific reference to “community experience.” In addition, the indicator is
very broad and includes a wide range of activities. As a result it cannot be used to
measure progress on just one of those activities. In 2009-2010, state scores on Indicator
13 varied between 3 percent and 100 percent with a mean of 80 percent calling into
question the validity and reliability of the reporting metric.
Indicator 14 attempts to capture the outcome of transition planning by surveying youth
after they leave school. Despite initial methodological challenges in collecting the data,
most states were able to report the measure for the 2010-2011 school year. On average,
32 percent of students were enrolled in higher education, 60 percent were either enrolled
in higher education or competitively employed and 77 percent were enrolled in higher
education, or in some other postsecondary education or training program, or
competitively employed. (Calculated from data available at US Department of Education,
2012). Because post school outcomes result from a variety of different factors, indicator
14 does not measure the availability of high school work experience.

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iii. History
IDEA’s transition provisions have evolved since its inception, which marked the
beginning of the requirement that people with disabilities between the ages of 3 and 21 be
offered a free appropriate public education in the least restrictive environment.
Legislation which modified the original IDEA includes:
Education of All Handicapped Children Act of 1975 (P.L. 94-142) established that in
order to receive federal funds, states must ensure that all students with disabilities have
the right to receive a free and appropriate public education in the least restrictive
environment. Legislation required testing and evaluation procedures, the development of
an Individual Education Plan (IEP), parent rights and due process
Education of the Handicapped Act Amendments of 1983 (P.L. 98-199) added an emphasis
on transition services. The legislation authorized federal funds to develop and
disseminate programs and best practices that included vocation, transition and job
placement services.
The Individuals with Disabilities Education Act of 1990 (P.L. 100-476) added transition
services and assistive technology services as new definitions of special education services
that must be included in the IEP. The legislation mandated that transitional services
include a coordinated set of activities with an outcome-oriented process and that all
students aged 16 years and older were to have a written individual transition plan (ITP) as
a component of their IEP. The ITP was to include a statement of interagency linkages
and their role and responsibilities in assisting the transition process. It established that
the IEP team would have a follow-up meeting if the interagency service provider failed to
provide any agreed-upon services in a student’s IEP/ITP.
The Individuals with Education Act Amendments of 1997 (P.L. 105-17) established that
beginning when the student is 14, the IEP must include a statement of the student’s
transition service needs “that focuses on the child’s courses of study (such as
participation in advance-placement courses or a vocational education program.”
Beginning at age 16 (or younger if determined appropriate by the IEP team), the IEP is to
include a statement of needed transition services, including, when appropriate, a
statement of the interagency responsibilities or any needed linkages (34 CFR
300.43(a)(2)).
In the current law, the Individuals with Disabilities Education Improvement Act of 2004
(P.L. 108-446), the definition of transition services was amended to emphasize a focus on
improving the academic and functional achievement of the student. In addition, in
response to complaints from both parents and local educational agencies that the 1997
law creates confusion as to what schools are obligated to provide to students at various
times, IDEA 2004 replaced the age 14/16 distinction with a uniform standard of age 16
that is “readily understandable by teachers and students” (S. Rep. No. 108-185, 2003).

16
b. Vocational Rehabilitation
i. Description
Title I of the Rehabilitation Act of 1973 (P.L. 93-112) (Rehabilitation Act), most recently
reauthorized under the Workforce Investment Act of 1998 (P.L. 105-220) (WIA), provides
for individual states to receive federal grants to operate a comprehensive VR program
designed to assess, plan, develop, and provide VR services to eligible individuals with
disabilities to prepare for, and engage in, gainful employment.
The Act defines “transition services” as “a coordinated set of activities for a student,
designed within an outcome-oriented process, that promotes movement from school to
post school activities, including postsecondary education, vocational training, integrated
employment (including supported employment), continuing and adult education, adult
services, independent living, or community participation (29 U.S.C. § 701 Sec 6 (37)).
Neither the Act nor the administrative rules specify a minimum age at which students
may become eligible for services nor do they include specific reference to services for
facilitating work experience while in secondary school.
Section 101(a)(11)(D) of the Rehabilitation Act requires the state VR agency to
coordinate with educational officials and to enter into a formal interagency agreement
with the state education agency. The agreement must outline the roles of the each agency
in providing transition services and identify who will be responsible for providing what
services.
The Act also requires VR be the payer of last resort for many services. VR is not
supposed to pay for a service if a similar, or comparable, benefit is available through
another provider (29 U.S.C. §721(a)(8)).
The Rehabilitation Act requires that if a state agency cannot provide vocational
rehabilitation services to all eligible individuals who apply for services, the agency must
develop an “order of selection” and serve individuals with the most significant disabilities
first for the provision of vocational rehabilitation services. Those eligible individuals
who do not meet the order of selection criteria will have access to services provided
through the agency’s information and referral system.
ii. Monitoring
Under the Rehabilitation Act, states are required to submit to the Commissioner of the
Rehabilitation Services Administration (RSA) annual reports on state performance.
Although each state is required to report the number of transition age youth (defined as
ages14-24), they are not required to report the number of youth that are more closely
aligned with high school age (e.g. 14-18) or the number of students served while in high

17
school. As a result, it is difficult to identify how significant a role VR plays for this
population.
In addition to the annual state reports, The Rehabilitation Act requires the Commissioner
of the Rehabilitation Services Administration (RSA) to conduct annual reviews and
periodic on-site monitoring of programs (29 USC Sec. 727 (a)(1)(A)). RSA typically
reviews 15-20 agencies per year (Department of Education, 2012)).
RSA revised its monitoring and technical assistance process in 2011 to include a special
focus on transition services and employment outcomes for transition age youth.
According to the Monitoring and Technical Assistance Guide (MTAG),“teams will
identify and assess the variety of transition services provided in the states, including
community-based work experiences and other in-school activities, and post-secondary
education and training, as well as the strategies used to provide these services” (US
Department of Education, Office of Special Education and Rehabilitation Services, 2010,
page 22. Italics added for emphasis).
Despite the mention of in-school activities, the MTAG does not require the review teams
to assess the availability of job search and job placement services for in-school youth.
Several questions about the role of VR in facilitating paid work experience are included
in an appendix to the MTAG. For example: A series of questions designed for school
personnel asks if the school has entered into interagency agreements with the VR agency
on a local level, the type of services that VR provides under the agreement and who bears
the cost. The appendix suggests that student VR clients be asked to identify the types of
services they receive based on a checklist that includes paid work experience.
However, these questions are optional and, as a result, not all monitoring reports address
the issue.
VR agencies are not specifically required to facilitate paid work experiences for high
school students so even if the monitoring process captured the relevant information, RSA
does not have a mechanism to require that they include the service.
iii. History
The current VR system grew out of a program in which the federal government provided
matching funds to states to help wounded veterans reestablish themselves after World
War I. In 1920, Congress expanded the veteran's program to include anyone with a
physical disability. The Social Security Act of 1935 made vocational rehabilitation a
permanent federal program.
The Vocational Rehabilitation Amendments of 1943 (Barden-LaFollette Act) broadened
the program's financial provisions, offered a comprehensive definition of vocational
rehabilitation, expanded services to include physical restoration, and required each state
to submit a written plan for approval by the federal agency as to how federal/state dollars

18
would be used; expansion of services included on a limited basis person who were
mentally handicapped and mentally ill; and, fostered separate agencies for general
rehabilitation and rehabilitation of persons who were blind.
The 1965 amendments modified the term disability to include people with “behavior
disorders.” This included people with drug and alcohol abuse issues and public
offenders. The number of beneficiaries exploded, the change quickly overwhelmed the
system, and VR officials had to streamline the process. The process became less
individualized and people with the most significant disabilities were not served well
(Minnesota Governor’s Council on Developmental Disabilities, 2006).
In 1973, Congress redirected the Act with passage of the Rehabilitation Act of 1974 (PL
98-221) The Act authorized a formula grant program of vocational rehabilitation that
focused on people with significant disabilities. The Act defined disability as a “mental or
physical disability which for such individual constitutes or results in a substantial
handicap to employment” and “can be expected to benefit in terms of employability for
vocational rehabilitation services.” In addition, it requires the state establish an “order of
selection” so that if it cannot provide services to all eligible individuals, it will serve
those with the most significant disabilities first. (P.L. 98-221 7(A)).
In order to reinsert flexibility and individualization into the process, counselors and
consumers would now work in close partnership to individualize services and each
counselor-consumer team would use a formal Individualized Written Rehabilitation
Program to help them develop and deliver services.
In addition to defining the role of the vocational rehabilitation system, the 1973 Act
established equal access as a “right” and addressed the removal of architectural,
employment and transportation barriers. Title V prohibits discrimination on the basis of
disability in programs conducted by Federal agencies, in programs receiving Federal
financial assistance, in Federal employment, and in the employment practices of Federal
contractors.
The Rehabilitation Act was amended six times between 1974 and 1993. These
amendments strengthened the emphasis on people with the most significant disabilities
(P.L. 95-602 (1978)); authorized rehabilitation agencies to provide supported
employment (e.g. job coaches) (P.L. 99-506 (1986)); and emphasized the importance of
empowering people with disabilities by involving them more fully in the construction and
annual review of their individual rehabilitation plans (P.L. 102-569 (1992)).
The Rehabilitation Act was incorporated into The Workforce Investment Act and
Rehabilitation Act Amendments of 1998 (P.L. 105-220). The Act was to provide a "one-
stop delivery system" for individuals needing help in securing employment and to
facilitate the sharing of employment resources (such as job leads) by involved agencies.
The Act set out that individuals with disabilities would be served by a variety of
programs and would not be strictly dependent upon vocational rehabilitation. The Act

19
was to have been reauthorized in 2003, but a variety of political and substantive policy
impediments have blocked progress. As of January 2013, the Act has not been
reauthorized.
c. Career and Technical Education
Several federal laws including the Americans with Disabilities Act, Section 504 of the
Rehabilitation Act, IDEA, the Perkins Act, and the Work Incentives Improvement Act
guarantee students with disabilities equal access to programs and services available to
students without disabilities.
i. Description
Career and technical education in secondary school has been transformed in the last 20
years. Until 1990, the vocational education system was focused on developing specific
job skills and was isolated from the academic curriculum. It was often thought of as a
“dumping ground” for academically inferior students.
Schools have been moving to a newer model that integrates academic and career-based
skills. The new model includes formats such as tech prep, career academies, school
registered apprenticeships, student internships, career-oriented high schools, and school-
based enterprises.
One advantage of this approach is that it provides children whose focus is primarily
vocational with a better general education that could allow for more flexibility later in
their careers. It also allows children whose primary focus is not vocational education to
obtain some career and technical skills. A disadvantage, though, is that it decreases the
concentration on developing particular skill sets needed for technical work.
In addition to training in schools, career and technical education (CTE) programs offered
by local school districts and employment support services offered through the
Department of Labor’s One-Stop Career Centers can potentially facilitate work
experience for high school students.
Although the nature of CTE varies by state and by school district, most secondary
schools offer at least one occupational program and many districts provide access to a
wide range of programs through CTE high schools. The programs use a combination of
school-based coursework and work-based learning. Examples of work-based learning
include cooperative education, internships and apprenticeships, school-based enterprises,
job shadowing and mentoring.
More than 95 percent of high school students take at least one CTE course during their
high school career and about one third of high school students take a concentration of
three or more related CTE courses before they graduate. However, CTE programs serve
a somewhat disproportionate share of students with disabilities. In 1998 students with

20
disabilities represented 2.8 percent of all high school graduates but 4.2 percent of all
occupational concentrators. The most commonly offered career clusters are: business;
computer technology, mechanics and repair, precision production, construction, child
care and health care (Levesque et al., 2008).
ii. Monitoring
States are required to submit a “Consolidated Annual Report” to the Department of
Education that includes data on six student performance measures at the secondary level:
(1) academic attainment in reading/language arts and math (2) technical skill attainment
(3) secondary school completion (4) graduation rate (5) student placement and (6) non-
traditional participation and completion. In addition to statewide totals, states must
provide data for each of eight special populations including students with disabilities.
States compare this annual data to specific performance targets that they negotiate with
the Department of Education. The Act stipulates the steps a state must make if it does not
meet at least 90 percent of its targets.
None of the performance measures require the state to report on the number of students
who participate in different types of programs such as school-based coursework and
work-based learning nor does it require state to report on the type of work-based learning
(e.g. hands-on job experience).
iii. History
Vocational education has evolved since the federal government established its role in in
the field in 1917 with the Smith-Hughes Act (P.L. 65-347). The Act established
vocational education as separate from the academic curriculum and focused on providing
narrow technical and production skills. The Act specified specific trades that should be
taught and required that vocational education students spend at least half their time
learning practical work skills. This act was updated and re-authorized many times, but the
first major change in the approach to vocational education occurred in 1963.
The Vocational Education Act of 1963 (P.L. 88-210) shifted the focus from providing
specific types of vocational programs to developing programs that served specific types
of students. The law stipulated that funds be used for persons who have a disability, are
disadvantaged, or have limited English proficiency. It specified that disabled students
should have access to regular vocational education programs. A 1968 amendment (P.L.
90-576) confirmed this commitment by requiring each state to earmark 10% of its basic
grant for services for youth with disabilities (Silverstein, 2000).
Carl D. Perkins Vocational Education Act of 1984 (P.L. 98-524) had two interrelated
goals. First, the law sought to improve the skills of the labor force and to prepare adults
for job opportunities. Second, it sought to improve the access to vocational education to

21
students who have been underserved in the past or those who have greater-than-average
educational needs. Under the act, "special populations" include those who have a
disability, are disadvantaged, or have limited English proficiency (Harvey, 2001).
The Carl C. Perkins Vocational and Applied Technology Education Act of 1990 (P.L.
101-392) represents a major shift in the way vocational education had been provided.
While earlier legislation separated and isolated vocational teachers, student and
curriculum from the rest of the school community, the Perkins Act of 1990 sought to
integrate academic and vocational education.
Subsequent reauthorizations and amendments eliminated the set-aside funding for special
populations but, in an effort to ensure equal access for special populations, the law
required each state to report progress on core indicators for program participants overall
and for each of the special populations.
Most recently, Congress reauthorized the Carl C. Perkins Vocational and Applied
Technology Education Act of 2006 (P.L. 109-270) despite pressure from the Bush
administration to shift the funds to academic education. The legislation changes the term
“vocational education” to “career and technical education.”
The Perkins Act was complemented by the School to Work Opportunities Act of 1994 (PL
103-239), which allocated funds to establish statewide partnerships to increase: (1)
school-based initiatives such as career links to academic curriculum and career-awareness
activities; (2) connecting activities, such as the development of partnerships with
employers and post-secondary institutions and (3) work-based activities such as job
shadowing, internships, and apprenticeships. It was established to bridge the gap
between education and work for all students, not just those participating in CTE. After
its initial five years, the STWOA was not reauthorized.
d. Employment and Training Programs/Workforce Investment
Act
In addition to the employment support services available through career and technical
education programs in public schools, at risk youth, including youth with disabilities,
may access the Department of Labor’s employment and training programs established in
the Workforce Investment Act of 1998 (P.L. 105-220).
WIA integrates multiple employment and training programs into a One-Stop delivery
system. Each local One-Stop system (recently renamed America’s Job Centers) is
comprised of numerous partners that provide services based on their authorizing
legislation. While the Act establishes certain minimum requirements for the structure of
the local system, it allows local communities significant flexibility in the design and
implementation of their One-Stop systems.
In addition, WIA requires states to establish Youth Councils and, under the direction of

22
these Councils, offer ten services to youth ages 14-21. (1) Tutoring, study skills training,
and instruction leading to secondary school completion, including dropout prevention
strategies; (2) Alternative secondary school offerings; (3) Summer employment
opportunities directly linked to academic and occupational learning; (4) Paid and unpaid
work experiences, including internships and job shadowing, (5) Occupational skill
training; (6) Leadership development opportunities, which include community service
and peer-centered activities encouraging responsibility and other positive social
behaviors; (7) Supportive services; (8) Adult mentoring; (9) Follow-up services; and, (10)
Comprehensive guidance and counseling (20 CFR 664.410).
WIA is targeted to low-income youth, however the legislation includes provisions to
ensure that youth with disabilities with higher family incomes have an opportunity to
participate. For example, when determining income criteria for eligibility, for youth with
disabilities WIA considers only the personal income of the teenager, not the income of
his/her family. As a result, most youth with disabilities qualify for services (National
Center on Workforce and Disability/Adult, 2007).
iv. Monitoring
WIA has two sets of performance measures for transition age youth. For older youth
(aged 19-21), states must report entry and retention in employment, earnings received,
and attainment of a recognized credential.
For younger youth (age 14-18), states must report the following (U.S. Department of
Labor, 2009):
 Attainment of basic skills and, as appropriate, work readiness or occupational
skills;
 Attainment of secondary school diplomas and their recognized equivalents; and
 Placement and retention in postsecondary education, advanced training, military
service, employment, or qualified apprenticeships.
In addition to statewide totals, the state must provide the data for special populations
including people with disabilities, public assistance recipients and out-of-school youth.
Each state negotiates an expected level of performance for a variety of indicators.
Technical assistance, sanctions, and Federal incentive funds are tied to whether States
meet the expected levels of performance.
v. History
WIA represents an evolution in the federal government’s approach to job training.
Previous legislation included the Manpower Development Training Act of 1962 (P.L. 87-
415) that launched the era of federal funding for employee training and development. It

23
authorized funds for a three-year program for training and retraining unemployed and
underemployed adults. It was replaced by the Comprehensive Employment Training Act
of 1973 (PL 93-203). CETA provided block grants to state and local governments to
support public and private job training and included youth programs such as the Job
Corps and Summer Youth Employment.
The Job Training Partnership Act of 1982 (JTPA) (P.L. 97-300) replaced CETA and
established programs to prepare youth and unskilled adults for entry into the labor force
and to afford job training to economically disadvantaged individuals. The statute enlarged
the role of state governments and private industries in job training programs, imposed
performance standards, created program for retraining displaced workers.
Both CETA and JTPA specifically allocated funds for summer jobs programs. WIA
modified this approach by requiring each local workforce area to have a year-round youth
services strategy that incorporates summer youth employment opportunities as just one of
ten required program elements. As a result, the number of summer jobs programs
dropped when WIA came into effect (Social Policy Research Associates, 2004). The
paucity of summer jobs programs continued until 2009 when the American Recovery and
Reinvestment Act provided additional funding for summer jobs programs for
disadvantaged youth.
3. Availability and Use of Work Experience
No data exist that document that percentage of students with disabilities who have work
experience over the course of high school and compares that figure to students without
disabilities. However, the 2003 wave of the Department of Education’s NLTS-2 provides
three measures of employment of students 15-19: employed at the time of interview;
employed at some time in past year; and employed at some time in the past two years.
Thirty percent of students with disabilities were employed at the time of the NLTS
interview in 2003. This percentage is less than that measured by the BLS’s Current
Population Survey. That data suggests that 36.4 percent of all teens 16-19 were
employed at any point in time in 2004 (Bureau of Labor Statistics, 2005).
Unfortunately, it is not possible to make the same comparison based on the other NLTS-2
data elements because BLS does not provide statistics on the percentage of teens
employed at any time over the past year or over the past two years. Nevertheless, the
other NLTS-2 data yield important findings.
According to the NLTS-2, 61 percent of youth 15-19 had been employed in the past two
years - some at work-study jobs, some at summer jobs and others at non-school-related
jobs during the school year. This rate varies significantly among disability type. As
shown in Figure 1, 69 percent of students with learning disabilities had been employed
but only 40 percent of those with intellectual disabilities and 18 percent of those with

24
autism.
Figure 1: Percent of high school youth age 15-19 with disabilities
employed in the last two years
Source: National Longitudinal Transition Study 2. (2003). NLTS2 data tables. Available
at: http://www.nlts2.org
The summer months represent a natural avenue for youth to gain community-based work
experiences. Holding a summer job represents a normative experience for youth without
disabilities. Descriptive studies, however, suggest that many adolescents with disabilities
remain uninvolved in work and community activities during the summer months
(Carter,et al., 2010).
According to the NLTS-2, 53 percent of youth 15-19 had summer jobs in 2003 (41% had
jobs both during the summer and school year, 13% had jobs during the summer only).
This is roughly equivalent to BLS data that suggest that more than half of all 16-19 year
olds work during the summer of 2005 (Bureau of Labor Statistics, 2006).
18%
23%
23%
31%
40%
47%
51%
57%
59%
61%
69%
71%
61%
0% 10% 20% 30% 40% 50% 60% 70% 80%
Autism
Deaf/ Blindness
Multiple Disabilities
Orthopedic Impairment
Intellectual Disability
Visual Impairment
Hearing Impairment
Emotional Disturbance
Traumatic Brain Injury
Speech Impairment
Learning Disability
Other Health Impairment
Total

25
However, like employment overall, summer employment varies dramatically among
disability types. For example, only 40% of teens with visual impairments, 32 percent
with intellectual disabilities, 26 percent with orthopedic impairments and 15 percent with
autism, worked during the summer (NLTS-2, 2003).
Despite the existence of programs to help youth get jobs during high school, evidence
suggests that few students use these services. For example, Carter et al. (2011b) found
that youth primarily found their jobs either on their own or with help from their parents,
other relatives, or friends. Reliance on teachers or school staff varied among disability
types. Only six percent of students with learning disabilities received help from school
staff in contrast to 12 percent of students with emotional behavioral disabilities and 36
percent of students with intellectual or developmental disabilities. No one reported
receiving help finding a job from vocational rehabilitation (Carter et al 2011b). The
NLTS-2 does not provide data on the job search experience of high school students but it
shows that among students with disabilities just out of high school seven percent received
help from an employment agency and five percent received help from school staff
(Newman et al., 2009).
Table 2: Source of Job Search Assistance among Youth
Summer Jobs while in high school1
Post-high school
jobs2
Emotional
/Behavioral
Disability
Intellectual/
Development
Disability
Learning
Disability
Youth with any
disability
1-4 years after
high school
Youth reported finding job
himself or herself
30%
14%
25%
50%
Youth had help from:
Family member (parent or
other relative)
42%
53%
55%
19%
Friend or acquaintance to
youth
27%
18%
24%
20%
Employment agency*
7%
Teacher/school
12%
36%
6%
5%
Other*
9%
6%
Sources: 1Carter et al. 2011, 2Newman et al. 2009.
* “Employment agency” was not an option in Carter et al. 2011b and “Other” was not an
option in Newman et al. 2009
Carter et al. (2010) found that schools offer an array of career development opportunities
but participation by youth with disabilities in these experiences varies and is generally
fairly limited. For example, 91 percent of schools offer career interest assessments and in
75 percent of those schools either some or most of students with severe disabilities used
the services. Almost all schools reported that some or most of the students with

26
emotional or behavioral disabilities (EBD) used the services. In contrast, only 44 percent
of schools offered job placement services for students and half of students with either
severe disabilities or EBD used the services. (Table 3)
Table 3: Availability and Accessibility of Career Development Activities
for Youth with Disabilities
Activities
% of Schools
offering the
service
% of schools offering the service that report some
or most of youth with disabilities use the service
Youth with severe
disabilities
Youth with emotional
and behavioral disorders
Career interest assessments
91
76
97
Job-shadowing Programs
82
36
43
Apprenticeship programs
71
9
13
Paid or unpaid internships
68
35
19
Cooperative education
programs
53
20
33
Job placement services for
students
44
53
46
Source: Selected data from Carter et al. 2010.
4. Barriers to Effective Programs
Youth with disabilities face a number of obstacles to working while in high school,
including parental and teacher expectations (Carter et al., 2011a), a mismatch between
work place skills and expectations (Trainor et al. 2010), limited awareness and
understanding on the part of employers (Joshi et. al, 2012) and others.
IDEA transition planning, Vocational Rehabilitation, Career and Technical Education
and Local One-Stop agencies are expected to help them overcome these obstacles.
However, the programs themselves have barriers that prevent them from working
effectively to promote high school work experience. This section describes the
weaknesses in each of the programs.
a. Schools and IDEA transition planning
The characteristics of the transition planning process vary by state, by school and by
characteristics of the youth and their family. Studies have indicated a number of barriers
as to why community work experience is often not included in transition planning:
1. Schools and special educators find it challenging to locate appropriate
opportunities. They perceive a paucity of employers willing to hire youth with
disabilities and they have limited training, time, resources and available avenues
to effectively conduct job development and build relationships with employers

27
(Carter et. al 2011b).
2. The increased focus on core academic areas, standards-based curricula and high-
stakes testing has shifted focus away from exploring student’s nonacademic goals
(National Council on Disability, 2008).
3. Students and families may have low expectations about the ability of the student
to work or may be unaware of the available opportunities. The IDEA process is
an opportunity to educate students and families about choice and expectations,
however students and families are often not adequately engaged in the IEP
transition planning process (Lowe, Morris & Kennedy, 2012)
4. The Department of Education requires that all states report on 20 indicators to
chart the progress of IDEA. Although two indicators are relevant for measuring
the strength of transition planning, neither effectively measures the availability
and use of community work experience.
b. Vocational Rehabilitation
Some state VR programs have developed comprehensive services and strong
collaborative relationships with special education programs at the state and local levels to
address the needs of transitioning students. However, anecdotal evidence suggests that
there is tremendous variation in both transition practices and the resources committed to
such practices among state VR agencies (Study Group, 2007). In addition to this
variation, the following stumbling blocks are common across VR agencies.
1. The Rehab Act describes transition services but makes no specific mention of job
search assistance or job supports while the student is still receiving services from
the school. As a result, many VR agencies see this role as outside their core
responsibilities.
2. Because VR is supposed to be the payer of last resort, they are limited in the
extent they can participate in providing services to children who are still in
school, which puts the responsibility in the school’s domain, even though it lies
outside their core competence. Moreover, financial incentives work against
collaboration, which limits cost-sharing. As a result, VR counselors generally
limit their involvement to development of transition IEPs and IPEs and providing
career counseling and guidance until the student leaves school.
3. The state and local interagency agreements are vital for the coordination between
VR and the education authority, however they have significant limitations:
4. The agreements often overestimate the capacity of the VR agency to fully
implement all of the procedures, processes, and services identified within these

28
agreements.
5. The agreements are often not specific enough concerning the roles and
responsibilities of each agency.
6. Mechanisms are not in place to determine whether procedures, processes, and
services specified in interagency agreements are carried out, or whether they have
the intended impact (The Study Group, 2007).
7. Key stakeholder groups have differing expectations about the services and level
of involvement that VR can currently provide to transition-age youth. Education
personnel want more communication with VR counselors, a consistent referral
process, and more work-based learning opportunities provided through VR for
their students (National Council on Disability 2008).
8. Local education agencies do not effectively engage VR agency personnel in the
planning and provision of transition services for transition-age youth (Study
Group, 2007). If VR is involved at all, it is late in the process. For example,
Cameto et al (2004) found that a VR representative was at 10 percent of IEP
meetings of 16 year olds and 25 percent of meetings for 17-18 year olds. Youth
with disabilities and their families are not always aware that their children may be
eligible for VR services during their high school years. For many students, it is
not until their final year in high school that the school requests approval from the
family for a referral to the local VR agency.
9. The order of selection requirements may make it unlikely that some groups of
transition-age youth (e.g., individuals with milder learning disabilities, Asperger’s
Syndrome, Attention Deficit Hyperactivity Disorder) will actually receive
services, despite that fact that they have been determined eligible for and could
benefit from the array of VR services (National Council on Disability, 2008).
10. States that have dedicated VR counselors who serve the transition population as
all or a set percentage of their caseload put a higher priority on transition
populations. However, only a few states have VR counselors assigned to local
school districts. For the other states, VR services are only provided to transition-
age youth upon request of the parent or when initiated by the school (The Study
Group, 2007).
11. The number of transition-age youth served by VR has increased steadily over
recent years and VR transition coordinators are finding it difficult to meet the
demand for involvement in the transition IEP (National Council on Disability,
2008).
12. The current methods for monitoring and evaluating RSA do not measure the
services provided to high school age students. Although each state is required to
report the number of transition age youth (defined as ages14-24), they are not

29
required to report the number of youth that are more closely aligned with high
school age (e.g. 14-18) or the number of students served while in high school. As
a result, it is difficult to identify how significant a role VR plays for this
population. RSA conducts annual reviews and periodic on-site monitoring of
programs and includes a special focus on transition services and employment
outcomes for transition age youth. However, this process does not require the
review teams to assess the availability of job search and job placement services
for in-school youth.
c. Career and Technical Education
Career and technical education has evolved over the past several decades to combine high
academic standards with technical skills. Policy and practicalities limit the amount of
hands-on work experience that CTE programs provide to students with disabilities.
1. The Perkins Act of 2006 focuses on school-based technical and vocational
education and guidance rather than hands-on work experience in a natural setting.
For example, the policy specifically includes provisions for the use of funding for
“information and planning resources” that bridge career and technical education
to the goals and expectations of consumers, and “guidance” and “counseling” to
aid decision making about “training options and preparation” for employment-
related goal setting (Carl D. Perkins Career and Technical Education
Improvement Act of 2006).
2. Although most stakeholders realized the benefits of authentic work-based
educational experiences such experiences are more difficult to provide than are
the school-based initiatives (Brown, 2002). As shown in Table 3, most schools
offered some work-based experiences. However, fewer offered services that have
been shown to be especially beneficial for youth with disabilities such as paid or
unpaid internships or job placement services. Even among schools that offer the
services, few of the schools report that most or even some of their students with
disabilities participated in the programs.
d. Employment and Training Programs/Workforce Investment
Act
WIA Youth Programs and other services and programs available within America’s Job
Centers have the potential to provide help finding work opportunities for youth with
disabilities. However, students with disabilities face two challenges in accessing these
services:
1. Many parents and students with disabilities as well as transition coordinators in
local education agencies are unaware of services available to youth through the
Workforce Investment Act, requirements of equal access, and effective and
meaningful participation requirements within WIA and other services and

30
programs at America’s Job Centers. Funding is available through WIA youth
programs and other programs through the Job Centers for after school work
experience and summer paid internships and employment opportunities. Youth
with disabilities qualify for these need-based programs regardless of their parents’
income. The disability status triggers the youth’s application to take only their
individual youth income and not their family’s income into account which results
in the youth falling into the low-income population which is the priority target
group for participation.
2. The performance requirements under WIA youth programs are often viewed as a
disincentive to serving youth with disabilities. Math and reading improvement
requirements, also known as “Literacy and Numeracy Gains”, attainment of a
degree and/or certification, as well as placement in education or employment in
WIA performance measures remain challenges at a local level that need additional
attention. Although performance requirements may be negotiated, there have
been few attempts by states to address these issues. Additionally, while guidance
has been provided from U.S. DOL-ETA through a Training and Employment
Guidance Letter (TEGL 13-09) to the states, Workforce Investment Boards and
WIA youth services providers detailing how to increase enrollments of youth with
disabilities while still meeting performance measures, this guidance has not been
acted upon since its deliverance in February of 2012.
e. Interaction with Social Security Programs
Special education students enrolled in Supplemental Security Income (SSI) through the
Social Security Administration will be more likely than those with similar characteristics
to remain outside of the labor market both during school and post-school because SSI
recipients may lose their cash and health (Medicaid) benefits if they start working
(Wittenburg et al., 2002).
In recent years, SSA has designed a number of work incentives to mitigate any negative
financial impact of working and promote employment among program recipients
including transition-age youth. For example, the Student Earned Income Exclusion
allows individuals under the age of 22 to earn up to $1,700 of earned income per month
($6,840 per year) without jeopardizing their SSI eligibility. Section 301 allows
beneficiaries to remain on SSI while completing an approved vocational rehabilitation
program or an individualized education program under IDEA.
In addition, SSA has initiated the Work Incentives Planning and Assistance (WIPA)
program that can helps youth understand the effect of paid employment on cash benefits
and public health insurance and how to use SSA work incentives to mitigate any negative
impact. Nevertheless, these work incentives are rarely used and receipt of SSI continues
to be a disincentive to work. Currently, the federal authority and funding of WIPA
grantees has elapsed.

31
Few youth access work incentives for a number of reasons:
1. Work incentives are difficult to understand for the individual with significant
disabilities and often require the assistance of certified benefit planners to be
utilized effectively in order to transfer off benefits or maintain benefits as needed
as part of a plan to increase income production and become less dependent on
public benefits.
2. Challenges also remain with the process of redetermination of eligibility for
Social Security benefits. Work experience while in high school has been found at
times as evidence that the individual in question has the ability to work and that
their disability is not severe enough to merit determination of continued eligibility
for benefits.
5. Recommendations
Multiple programs share responsibility for helping students with disabilities find and
maintain a job while in high school. However, limitations exist within each program and
in the interaction between the programs. Improving the system requires multiple
agencies to make regulatory changes and take administrative actions. This section
focuses on modifications to IDEA, Vocational Rehabilitation, and SSA. Although CTE
and WIA programs bear some responsibility for the outcome, modifying the three
disability programs is likely to have the most significant impact.
1. Modify Section 612(a) of IDEA by adding a new paragraph that requires all states
to develop a plan for transition services that describes specific approaches and
activities to coordinate services and resources including support of work
experience while still in school and the successful transition of youth with
disabilities into adulthood. Amend Section 612(a) by adding a new paragraph
(26):
The state has established a plan with public input to ensure the State
educational agency coordinates efforts with other state agencies including
the state Vocational Rehabilitation agency, the state agency responsible
for the state Medicaid program, the state Department of Labor, the state
Intellectual and Developmental Disabilities agency, and the state Mental
Health and/or Behavioral Health agency to increase the availability of
resources to support integrated, competitive work experience for students
with disabilities beginning at age 16 that provides opportunities to interact
continuously with nondisabled coworkers and develops critical skills for
work and career readiness as part of successful transition into adulthood
post completion of secondary education. Such experiences do not include
day habilitation centers, facility based employment and activity settings
such as sheltered workshops, or mobile work crews and enclave work

32
settings. Such a plan details the level and scope of coordinated activities
to improve work-based learning experiences, career preparation and skills
development, and job experiences in an integrated community setting.
2. Amend the list of services available under the Rehabilitation Act (Section 103a)
to include: pre-employment transition services that provide to students with
disabilities at a minimum i) job exploration counseling; (ii) work-based learning
experience, including in-school and after school work experience, or work
experience outside the traditional school setting (such as experience through job
training or internships), that is provided in an integrated environment to the
maximum extent possible. The Workforce Investment Act of 2012 (H.R.4227),
which stalled in the 112th Congress provides the following specific language that
clarifies that role that VR should play in pre-employment services (including high
school work experience):
‘‘(A) IN GENERAL.—The term ‘pre-employment transition services’
means a coordinated set activities for an eligible student with a disability,
designed within an outcome-oriented process, that promotes movement
from school to any of the following post-school activities: postsecondary
education, vocational training, competitive integrated employment
(including supported employment), adult education, adult services,
independent living, or community participation.
‘‘(B) SPECIFIC SERVICES.—The term ‘pre-employment transition
services’ means a set of services, that is available to students with
disabilities, and that makes available, at a minimum— (i) career
counseling; (ii) work-based learning experience, including in-school
and after school work experience, or work experience outside the
traditional school setting (such as experience through job training or
internships),that is provided in an integrated environment to the
maximum extent possible; ‘‘(iii) counseling on opportunities for
enrollment in a comprehensive transition or postsecondary educational
program at an institution of higher education; (iv) school-based
preparatory employment experiences such as role playing, social skills
development, and independent living training, coordinated with any
transition services provided by the local educational agency under the
Individuals with Disabilities Education Act (20 U.S.C.8 1400 et seq.); and
‘‘(v) training in self-advocacy, individual rights, self-determination skills,
and the informed consent process, as well as peer mentoring.
3. Modify performance report requirements for state Education agencies to indicate
what number and percentage of students with disabilities have indicated in their
IEP the participation in work experience in an integrated community setting to
meet post-secondary goals regarding employment and what number and
percentage of students actually participated in such work experience for a

33
minimum of four weeks that is at least 15 hours a week.
4. Modify the reporting requirement of state Vocational Rehabilitation to include
school age youth ages 14-18 and modify the Monitoring and Technical Assistance
Review to assess the availability and use of job search, job placement and job
support services for in-school youth.
5. Instruct the Department of Education and the Department of Labor to issue joint
guidance to their respective state agency counterparts that encourages the support
of work experiences in integrated community settings as an evidence-based
practice that improves post-secondary employment outcomes for students with
disabilities.
6. Instruct SSA to issue guidance to their field offices and all SSI and/or SSDI
beneficiaries between the ages of 14 and 18 that encourages students with
disabilities to seek out and participate in work experience in integrated
community settings. The guidance would state clearly the work incentives that
can be applied during age 18 re-determination that may demonstrate that although
an individual is working their disability continues to impede them from working
at a substantial level, indicating eligibility for Social Security disability benefits.
In addition, SSA a) expands the student earned income exclusion to disregard all
earned income for students under age 22 who are regularly attending school, and
b) suspends, until age 22, the age 18 re-determination for any SSI recipient who is
working a minimum of 10 hours per week and is regularly attending school.
7. Adopt the Transitioning towards Excellence in Achievement and Mobility
(TEAM) legislation introduced in 2011 in Congress would help support greater
opportunities for students with disabilities to participate in work experiences as
part of transition services and authorize new funding to improve the scope of
services available through state and local education agencies as well as the state
Vocational Rehabilitation agency.

34
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