CPSD believes that the fully realized implementation of the WIOA Advisory Committee Report recommendations will result in a dramatically different system of CIE employment supports from what is available today. It recognizes that such a system will necessitate time and the full participation of all key stakeholders to effect change. In order to ensure on-going, continued commitment to this expansive degree of systemic reform, CPSD calls for the on-going accountability of those most responsible by:

  1. Requiring an Annual Report to Congress on the status and progress of implementing the WIOA Advisory Committee’s Recommendations; and,
  2. Requiring the involvement of the Office of Management and Budget in the shift to paying for different outcomes through system modernization and alignment

To begin the more immediate implementation of the WIOA Report Recommendations, CPSD calls for:

  1. An Interagency Task Force be established within 100 Days of next administration, to include the Office of Management and Budget

Congress should direct the formation of an interagency task force to develop an implementation plan for these capacity-building steps for increasing CIE and advancing economic self-sufficiency. At a minimum, this task force should include representatives from: DOL (ETA and ODEP), ED (RSA, OSEP), HHS (SAMHSA, CMS, ACL), SSA, DOJ, Federal Deposit Insurance Corporation (FDIC), and Treasury. (p. 19)

  1. Congress to pass legislation for multi-year phase out of FLSA Section 14 c subminimum wage provision

Congress should amend Section 14(c) of FLSA to allow for a well-designed, multi-year phase-out of the Section 14(c) Program that results in people with disabilities entering CIE. (p. 107)

  1. The Creation of a third party evaluation of Source America and increased data reporting of Ability One

Congress should authorize an independent third-party evaluation tasked with studying the implementation of the recommendations as submitted herein, and submit a report that identifies and recommends additional policies that may be required to implement the changes necessary to reform the JWOD Act as indicated above. (p. 60)

  1. An analysis in detail of the requisite alignment of Federal Systems

Congress should reauthorize IDEA and the Carl Perkins Career and Technical Education Improvement Act to align with WIOA and expand responsibilities of programs funded through the Act in order to support early paid work experiences for youth with the most significant disabilities.  (p. 23)

  1. An OMB review and analysis and recommendations for improved interaction of the benefits system with employment outcomes

Read CPSD’s Full Response HERE.

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