In June, CPSD submitted comments on the proposed regulations for Title IV of the Workforce Innovation and Opportunity Act to the Rehabilitation Services Administration of the Department of Education. Please find the comments and cover page linked below.
Among issues raised are the following concerns:
- The regulations for implementation of Section 511 of WIOA intended to limit the use of subminimum wage, are extremely problematic, in particular the wide degree of discretion given to the public VR system, in terms of who these regulations apply to. This level of discretion could result in Section 511 having little if any impact, and is not all in keeping with the much more encompassing scope of Section 511 intended by Congress. We have provided a number of suggestions for a much more pro-active approach for abiding by the requirements of Section 511.
- While we are pleased to see the increased role of public VR within Pre-Employment Transition Services, we have a number of concerns with this section. Specifically, we are concerned about the possibility that Pre-Employment Transition Services will result in a focus on “readiness-type” activities. These activities are of little benefit and create another needless hurdle for young people with disabilities to enter employment. We would prefer a focus on the best job readiness program there is – actual experience in real work places that reflect the features of employment outcomes under the definition of Competitive Integrated Employment. We have suggested changes in language to ensure this is the emphasis of Pre-Employment Transition Services.