Preparing for Your Disability Program ROCA

Preparing for Your Disability Program

ROCAPresented By: Laura Kuhn, Regional Disability Coordinator

2

Agenda

What is the Disability ROCA?

What Happens Prior to the ROCA?

Documents and Materials to Have Ready

Staff and Student Interviews

ROCA Scoring

Disability Program Requirements

Improving Your ROCA Score

The Brief-Out and ROCA Report

Be Prepared!

Resources

3

What is the Disability Program ROCA?

4

What is the Disability Program ROCA?

Part of the Regional Office Center Assessment (ROCA)

Conducted every 1 to 2 years by a staff member (assessor) of the accommodation support contractor as part of the ROCA team

Program Assessment Guide (PAG) is used to conduct an overall assessment of your center’s Disability Program

Similar to accreditation assessments that occur at health facilities nationwide

Provides an opportunity to highlight strengths of your program (best practices) and to identify any concerns, challenges, or practices that may require change in accordance with the PRH

5


6


Center receives an introduction memo and Pre-ROCA questions from the assessor approximately 3 weeks prior to the visit

Introduction memo provides the dates of the assessment (typically 2 days), documents needed during the assessment and a request to arrange a staff/student interview schedule

Quick Tips!• Read your memo thoroughly – it provides everything you

need to be well prepared• Complete the Pre-ROCA questions prior to the assessment• Review Policy

7


Review all Disability-Related Policy!

PRH Chapter 1

• 1.4, R1-4

• Appendix 107

PRH Chapter 2

• 2.2, R1 (b11), (d4)

• 2.2, R2

PRH Chapter 3

• 3.21, R2(g)

PRH Chapter 5

• Exhibit 5-1

• Exhibit 5-2

• Exhibit 5-4

PRH Chapter 6

• 6.14

• Appendix 605

• Appendix 607

8


The Disability Coordinator Desk Reference Guide and the Disability Coordinator Orientation on the Job Corps Disability Website are great places to review policies, procedures and obtain guidance for the Disability Program

Disability Coordinator Orientation webinars are offered quarterly

9


10


All requested documents and materials should be in one location and organized for the assessor

Provide a written list of all disability-related activities held on center including National Disability Employment Awareness Month, speakers, newsletters, webinars attended (certificates)

11


STANDARD OPERATING PROCEDURES (SOPS):

Disability Coordinators’ Roles and Responsibilities

Applicant File Review Process

Reasonable Accommodation Process

Quick Tips!• Use the sample SOPs on the Job Corps Disability Website

12


APPLICANT FILE REVIEW:

Applicant File Review Log

Quick Tips!• A sample file review log is available on the Job Corps

Disability Website

13


REASONABLE ACCOMMODATION:

Copies of Email notifications to staff regarding student accommodation plans

Accommodation files

Disability/no accommodation files

Career transition readiness materials/curriculum provided to students

Quick Tips!• Staff emails should include all accommodation plans

noting new and updated plans• Career Transition materials are available on the Job Corps

Disability Website

14


INTRODUCTION TO CENTER LIFE:

Materials provided to new students (e.g., brochures, reasonable accommodation request form, copies of presentations)

Student handbook

Quick Tips!• A brochure template is available on the Job Corps

Disability website• Sample Disability Program handbook language is available

on the Job Corps Disability Website

15


CIS REPORTS:

Recent monthly data review memos

Data Collection Report

Accommodation Plan with Notes Report

TABE Testing Accommodations Report

Quick Tips!• Respond to monthly data reviews and get help from your

Regional Disability Coordinator (RDIC) if unsure how to correct noted concerns prior to the ROCA

• Audit data collection and accommodation plans prior to the ROCA and on a regular basis.

16


STAFF ACCESS REPORTS:

CIS3g staff access reports for all disability-related entry screens and reports

CIS authorization/staff access reports for disability data, reasonable accommodation plan, reasonable accommodation plan w/notes

Quick Tips!• Reports are available from the center IT point of contact• Check access prior to the ROCA and on a regular basis. A

staff access graphic is available on the Job Corps Disability Website.

17


PARTNERSHIPS:

Disability Partnership Tool

REFERRAL PROCESS:

Referral/feedback forms used

Quick Tips!• Include all partnerships that provide services to students

with disabilities on your center/contacts made• Sample referral forms are available on the Job Corps

Disability Website

18


READILY ACHIEVABLE BARRIER REMOVAL:

Americans with Disabilities Act (ADA) Checklist for Readily Achievable Barrier Removal

Center Accessibility Tool

Accessibility Plan with priorities and next steps based on the results of the ADA checklist and Center Accessibility Tool – meeting notes from annual updates

Quick Tips!• Ensure all components of this process are completed

including the updated 2011 ADA Checklist• Provide meeting notes from annual updates

19


TRAINING:

Documentation of annual Disability Program training for all staff

Documentation of new hire staff (within 90 days) Disability Program Orientation Training

Quick Tips!Provide staff sign-in sheets, topic and a copy of the materials presented/provided. If using SIMON for new hire staff training, provide copies of staff certificates.

20

Staff and Student Interviews

21

Staff and Student InterviewsIndividual Interviews

Assessors will ask for individual interviews with the following staff members:

Disability Coordinators (DCs) Health & Wellness Manager (if not a DC)

Academic Manager (if not a DC)

Career Transition Readiness Manager

Center Mental Health Consultant

Counseling Manager

Records Manager

TABE Administrator

Other staff members may be requested during the ROCA

22

Staff and Student InterviewsGroup Interviews/Individual Student Interviews

Assessors will ask for group interviews with the following staff members:

Group Interview 1:

• Academic, Career Technical and Career Preparation Period (CPP) instructors (at least one CPP instructor, 3 Academic and 3 Career Technical instructors)

Group Interview 2:

• Business Community Liaison (BCL), Center Standards Officer, Residential Manager, Work Based Learning Manager

On the first day of the ROCA, you will be provided with a list of students with accommodation plans whom the assessor will interview on the 2nd day of the assessment

23

ROCA Scoring

24

ROCA Scoring

The PAG is used to score each of program requirement areas:

0/1 – Unsatisfactory - Critical requirements are missing – quality not achieved

2/3 – Marginal - Requirements and/or quality indicators are missing and quality assurance is minimal

4/5 – Satisfactory - Requirements and quality indicators are generally evident (requirements have been met)

6-7 – Very Good - Requirements are consistently met – innovative approaches are employed to promote continuous improvement

8/9 – Exceptional – Quality delivery of all requirements and achievement of quality indicators - Innovative approaches result in program enhancements and improved outcomes

25

Disability Program Requirements

26

Disability Program RequirementsDisability Coordinator

Disability Coordinator [6.14, R1(a-b)]

The Health & Wellness Manager (or a health staff designee) and Academic Manager (or an academic staff designee) will function as DCs to oversee the program

Additional DCs may be appointed

Centers may choose to hire a full or part time DC to oversee the program rather than or in addition to appointing an academic and health DC

The roles and responsibilities of each DC will be defined in an SOP

Quick Tips!• Use the sample DC Responsibilities SOP on the Job Corps

Disability Website to detail the roles of the DCs on your center

27

Disability Program RequirementsApplicant File Review Process

Applicant File Review Process [6.14, R2(a-c); 1.4, R1-4; Appendix 107; Exhibit 5-1]

There is an applicant file review SOP that describes the applicant file process in detail

Applicant files should be processed in 30 days of receipt by the center

Quick Tips!• Use the sample File Review SOP on the Job Corps Disability

Website to detail your applicant file review process

28


The file review procedure (SOP) should contain: Location where files are sent and logged in upon arrival to the center

The method of tracking the movement of the file to include an explanation of the center’s disposition of the file

Responsibilities and roles of applicant file review team members which include the Health & Wellness Manager, center clinicians, and the center’s DC(s)

Procedures for reviewing an applicant file to include acceptable reasons for recommending denial of an applicant

Procedures for reviewing and determining reasonable accommodation

Procedures for processing application withdrawals both before and after submitting a file for regional review

Timeframe the center establishes to complete the file review process to ensure it meets the PRH required timeframe of 30 calendar days

Storage, transmission and maintenance of the applicant file information (see Appendix 607)

29


The File Review Quick Quiz1. The file review committee should only include the Health & Wellness Manager, center

clinicians and DCs

TRUE!

2. The records manager is the file review coordinator

FALSE!

3. The only reason a file should be returned to Outreach and Admissions is 1) if the student withdraws or 2) the center cannot reach the applicant to conduct a clinical interview; and all supporting documentation of this is maintained with the file review log

TRUE!

4. An example applicant file review log is not located on the Job Corps Disability Website

FALSE!

5. You should start from scratch when writing your File Review SOP

FALSE!

30

Disability Program RequirementsReasonable Accommodation

Reasonable Accommodation Process [6.14, R3(a-c); Appendix 605; 3.21, R2G(g); Exhibit 5-1]

There is an SOP describing the reasonable accommodation process which includes all components outlined in Appendix 605

Quick Tips!• Use the sample Reasonable Accommodation SOP on the

Job Corps Disability Website to detail your reasonable accommodation process

31


Reasonable Accommodation Committee (RAC) Quick Quiz

1. The following individuals should be members of the centers’ RAC:

A. All departments that interact with students

B. The HWM, center mental health consultant, center physician, dentist, TEAP and DCS only

C. Only the DCs

ANSWER: (A) – all departments that interact with students may at some time or another be needed to sit on your RAC meeting

EXAMPLE: If you have a student with mobility issues, you may need the safety manager, food services, residential, recreation, etc.

32


Requesting Accommodation

• Are requests being documented using the most current Reasonable Accommodation Request form located in Appendix 605?

• Are request forms being filled in and completed by the DC and applicant/student?

Determination of Need

•Is the process between the center and applicant/student (and parent/guardian, when appropriate) to determine accommodation needs interactive?

•When there is documentation in the applicant’s file that a disability may exist is there documentation of an interactive process to determine the need for accommodation?•Reasonable Accommodation Request Form - Program (or)•Reasonable Accommodation Review Due to Documentation of Disability Form

Ensuring Appropriate Documentation

• Does the documentation support the accommodations provided?

• If the Center Mental Health Consultant is doing testing/evaluations are assessments and procedures available for review?

33


Reviewing the Request

• Do plans include technology that assists the student in becoming independent (e.g., books on tape, colored overlays, reading pens)?

• Are requests for accommodation handled in a timely manner?

• Are meetings/telephone contacts documented?

Determining Reasonableness

• Do accommodations align with functional limitations?• Is each request evaluated individually, and a

determination made regarding whether it is reasonable?

• Are you aware that center’s cannot deny accommodations?

• Are you familiar with the accommodation denial process?

• Do you know how to request funding from the National Office for high cost accommodations when no other funding sources are available?

Entering the Plan

• Are plans entered soon after a student arrives and before the first TABE test if TABE testing accommodations are provided?

• Are accommodation plans signed by the student and DC?

• Is a copy of the plan provided to students?• Is there a copy of the signed plan in the

accommodation file?

34


Notification

• Are bi-weekly emails with a list of all students with accommodation plans sent to all staff who work directly with students?

• Does the email indicate students who new or updated plans?

• Do you maintain copies of these emails?• Do managers ensure implementation of plans, how do

they do that?

Determining Accommodation Effectiveness

• Are accommodation effectiveness reviews done during the student’s 60-day ESP?

• Is student feedback documented?• Is feedback from staff who provide accommodations

documented?

Documenting the Process

• Is the entire process documented from prior to entry until separation?

• Is this documentation entered in the CIS Notes Tab?

35


Maintaining the Accommodation File

• Do accommodation files contain all required documents?

• Are you using a consistent layout for all files?

Storing Documentation

• Have Disability/No Accommodation files been created and contain all required information?

• Are these files stored as a group in a separate drawer, file cabinet, or storage room that is locked?

• Is confidentiality and “need to know” enforced? Who has access to these files?

• Are these files sent to records when a student separates?

Coordinating the Process• Are the DCs coordinating the center’s reasonable

accommodation process?

36


Career Transition Readiness

• Are all students receiving information about workers’ rights and responsibilities including reasonable accommodation in the workplace?

Quick Tips!• See the Job Corps Disability website for ready-made

transition materials and plans

37


Available on the Job Corps Disability Website

38

Disability Program RequirementsIntroduction to Center Life

Introduction to Center Life [6.14, R4(a-c); 2.2, R1(b11); 2.2, R1(d4), R2]

The center provides new students with information about opportunities and benefits available in the center’s Disability Program

The center provides a variety of opportunities for new students to meet and interact with the DCs

The student handbook includes information about the Disability Program

Quick Tips!• A sample reasonable accommodation brochure is

available on the Job Corps Disability Website• Language for the handbook is available on the Job Corps

Disability website – just copy and paste!

39

Disability Program RequirementsCIS Disability Data and Accommodation Plans

CIS Disability Data Collection and Accommodation Plans [6.14, R4(a-f)]

A DC accurately enters the required data in the disability data collection and accommodation plans in CIS soon after the student enters the program

Data is entered prior to the administration of the first TABE test for students with TABE accommodations

Only the DCs will have access to the disability data collection entry screen, disability data report and the accommodation plan report with notes report in CIS

Only DCs or designee will have access to the accommodation plan entry screen

All center staff responsible for providing accommodations have access to the accommodation plan report in CIS

Accommodation plans do not contain any medical or diagnostic information

40

Disability Program RequirementsPartnerships and Resources

Partnerships and Resources [6.14, R6(a-c)]

Center is developing disability-related resources and partnerships

The BCL staff and other appropriate staff are involved in this process

The center is documenting efforts to develop resources and partners by completing the Disability Partnership Tool or customized Disability Partnership Tool

Quick Tips!• The Disability Partnership Tool is available on the Job

Corps Disability website or contact your RDIC to get your customized Partnership Tool

• The BCL may already have good contacts that can become partners and provide services to students with disabilities

41

Disability Program RequirementsReferral Process

Referral Process [6.14, R7(a-b)]

A written referral/feedback system has been established to document the referral to the DCs

All referral forms are stored in students’ accommodation files, the Disability/no Accommodation file if the student has a disability, or in the student health record if no disability exists

Quick Tips!• A sample referral form is available on the Job Corps

Disability Website• Most centers place the form on the “S” drive• Train center staff to use this – do not accept only phone

calls or emails

42

Disability Program RequirementsReadily Achievable Barrier Removal

Readily Achievable Barrier Removal [6.14, R8(a-e); Exhibit 5-2)]

The center has determined potential improvements to the physical accessibility by completing the ADA Checklist for Readily Achievable Barrier Removal

The center has determined potential improvements to the programmatic accessibility by completing the program Center Accessibility Tool

The center has developed an accessibility plan with priorities and next steps based on the results of the ADA Checklist for Readily Achievable Barrier Removal and Center Accessibility Tool

The accessibility plan is reviewed and updated annually (June 30th)

The safety and facilities maintenance staff play a primary role in completing the plan with support from managers in all areas

43


Readily Achievable Barrier Removal [6.14, R8(a-e); Exhibit 5-2)]

www.adachecklist.org

Job Corps Disability Website

Quick Tips!• Tools to complete this requirement:

ADA Checklist for Readily Achievable Barrier Removal Center Accessibility Tool Sample Accessibility Plan

44


Suggested Practices:

Assign safety and facilities staff to complete the Checklist for Readily Achievable Barrier Removal

Use a portion of the management team meeting to assign staff appropriate areas of the Center Accessibility Tool

Assign an administrative staff person to incorporate the findings from the checklist and tool into a plan, cut and paste using the sample plan

Use a portion of a management team meeting to review contents of plan, determine any actions that can be taken, and establish priorities and timelines

Use a portion of a June management team meeting to update the plan annually

Get students involved; for example, students in carpentry may complete sections of the ADA Checklist

45


The Readily Achievable Barrier Removal Quick Quiz

1. If the center completed the ADA Checklist for Barrier Removal a few years ago, you don’t need to have it redone

FALSE!

2. The DC should send appropriate sections of the Center Accessibility Tool to corresponding staff members working in that particular area and request that they complete their section of the tool

TRUE!

3. Where can you find a sample Accessibility Plan?

On the Job Corps Disability Website of course!

46

Disability Program RequirementsStaff Training

Staff Training [6.14, R9; Exhibit 5-4]

The center is providing annual all staff training on the Disability Program

The center is providing New Hire Staff Disability Program Orientation (first 90 days)

Quick Tips!• Secure copies of the sign-in sheets for annual training and

sign-in sheets or copies of certificates for new hire staff training

• Training suggestions are available on the Job Corps Disability Website and disability orientation is available in SIMON, “Supporting Students with Disabilities in the Job Corps Program.”

47

Disability Program RequirementsQuality Indicators

Quality Indicators

Q1 – Students are able to identify and access appropriate disability-related supports and/or services to meet individuals needs

Quick Tips!• Students with accommodation plans are familiar with

DCs/Disability Program• Students report they were contacted prior to arrival to

discuss their accommodation needs• Students know who to ask if they have a disability or

accommodation concern• The center assists students in obtaining GED/certification

exam accommodations

48


Quality Indicators


Quick Tips!• There is a center-wide approach to providing accommodations (not

just for academics)• Students are signed up for Vocational Rehabilitation (VR), Centers

for Independent Living or other supports• Outside professionals/organizations were brought on center to

speak with students about understanding accommodations in the workplace, community resources available to them, were provided with benefits counseling, etc.

49


Quality Indicators


Quick Tips!• Students with accommodation plans should know

something about the Disability Program and who the DCs are

• Students report they were contacted prior to arrival to discuss their accommodation needs

• Students know who to ask if they have a disability/accommodation concern

50


Quality Indicators

Q3 – Accommodation plans demonstrate employability readiness by featuring accommodations that foster student independence

Quick Tips!• Accommodation plans are not geared towards testing or just

classroom accommodations• Accommodation plans are provided to students with a variety of

disabilities

51


Quality Indicators

Q3 – Accommodation plans demonstrate employability readiness by featuring accommodations that foster student independence

Quick Tips!• Students with behavioral issues are provided behavioral plans and

supports• Accommodation plans include assistive technology (books on

tape, colored overlays, or other assistive technology• Students understand how accommodations relate to the work

environment (WBL/Career Transition)

52


Quality Indicators

Q4 – Staff is aware of Disability Program requirements and their individual role in supporting students with disabilities

Quick Tips!• Required SOPs are completed and approved by the region• Staff know the DCs, their role and a basic understanding

of the reasonable accommodation process• Staff can name some accommodations and participate in

accommodation effectiveness reviews• DCs attend monthly DC calls and webinars on a regular

basis

53


Quality Indicators

Q4 – Staff is aware of Disability Program requirements and their individual role in supporting students with disabilities

Quick Tips!• Staff can articulate the written referral/feedback process• All required staff training was completed and staff can

recall some details of the training

54


55


Disability Coordinators

Center hires a full or part-time DC or has dedicated hours for the DC position

One or both DCs have a specialty (in VR, special education, mental health)

DCs are well know on center; staff know who to ask about disability-related issues or reasonable accommodation

56


Applicant File Review

Consider developing a locked folder on the share drive to improve communication throughout the process

Reasonable Accommodation

There is extensive monitoring and case management for students with accommodation plans

Career Transition Services provides students with a Career Planning and Transition Handbook. This handbook contains information on requesting reasonable accommodations for students with disabilities.

There are student-driven accommodation request forms offering an opportunity to discuss their disability

57


Introduction to Center Life

DC meets with each new student to explain the accommodation process and determine if the student would like to make a request

Have the disability brochure available in several areas around center

Put posters in several prominent areas around center that focus on individuals with disabilities – the Job Corps Disability Website has several free resources

CIS Disability Data Collection and Accommodation Plans

The CIS notes documents consistently documents the entire reasonable accommodation process including attempts to request accommodations for GED and certification exams

The Health & Wellness Manager maintains detailed outcomes data (e.g., academic and career technical gains, separation category, etc.) for students with disabilities. She then uses this data to compare outcomes for students with disabilities to those students without disabilities. She also looks at disability specific (e.g., learning disability, mental health disability) data to see if there are disabilities that may need more focus or are being served with increased frequency by the center. This data is used to guide staff training needs

58

Improving your ROCA Score

59


Partnerships and Resources

While all centers are required to have disability-related partnerships, this center goes above and beyond in the number of partnerships and the direct services students receive as a result of these partnerships

The center is a member of the City’s Disabilities Collaborative, a networking group of community organizations that helps build collaborative relationships to better serve people with disabilities. The DCs take turns attending the monthly meetings to network with potential disability partners and have expanded their disability partnerships as a result of this membership.

Secure services for students with disabilities while on center and when they leave, VR, Centers for Independent Living, etc.

The center has worked with the state assistive technology program to acquire adaptive equipment for a student

60


Readily Achievable Barrier Removal

The plan is updated yearly by a group of staff including the center director, maintenance supervisor, safety officer, manager of safety/security, finance and administration director, career development services system director, pathways manager, the social development director, and the disability coordinators

The facility maintenance and safety managers worked with the carpentry instructor to have students complete the ADA Checklist for Readily Achievable Barrier Removal. Students pasted pictures to the checklist to support their findings and suggest improvements.

61

Improving your ROCA Score

Staff Training

Provide more than the required annual staff training (monthly, quarterly, at Friday weekly meeting)

Train students how to advocate for their needs, understand community supports and the resources available to them for workplace accommodations, community resources, benefits counseling

Provide documentation of staff attendance from disability-related webinars

Include outside speakers

62

The Brief-Out and ROCA Report

63

The Brief-Out and Report

Upon completion of the assessment, the assessor will meet with DCs, management team and regional staff to provide an overview of positives and weaknesses from the assessment

A report will be provided to the regional office about 30 days after the review, the report is provided to the center director by the regional project manager (PM). Contact your PM if you do not receive the report.

Once reviewed, the center is asked to complete a Center Action Plan to address weaknesses and how the center plans on correcting these weaknesses

Quick Tips!• If the center has questions regarding the weakness and

how to respond, contact the RDIC for assistance

64

Be Prepared!

65

Be Prepared!

Send the interview schedule and Pre-ROCA questions to the assessor prior to the assessment

Have all documents and materials ready for assessment

Have a place set-up for the assessor to work

Have all interviews scheduled in the least amount of locations so the assessor can get to everyone and stay on schedule

DCs should plan to be available throughout the 2-day assessment for questions and assistance

Consider areas that technical assistance (TA) would be helpful – the quicker the assessment can completed, the more time the assessor will have to provide TA

66

Resources

67

Resources

Disability Coordinator Desk Reference Guide

Reasonable Accommodation Committee Guide

Job Corps Community Disability Website

Job Corps Community Event Registration – Webinars

Monthly Disability Coordinator Teleconference Call/Webinar

Regional Disability Coordinators:

Boston, Atlanta and Philadelphia Regions – Kristen Philbrook

• [email protected]

Dallas Region – Laura Kuhn


Chicago and San Francisco Regions – Kim Jones


mailto:[email protected]



68

Resources

Job Corps Disability Website

69

Questions?

Preparing for Your Disability Program ROCA

Documents

Transcript of Preparing for Your Disability Program ROCA