WIOA Plan Public Comment
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Public Comments The draft Workforce Innovation and Opportunity Act (WIOA) Combined State Plan was posted on the Pennsylvania Workforce Development Board’s webpage for public comment from December 28, 2015, through February 1, 2016. Stakeholders and the general public were notified of the posting of the plan and the opportunity to provide comment. The following pages capture each comment as submitted and a response. The commonwealth will continue to reference the comments as we implement the Workforce Innovation and Opportunity Act. Corrine Dietrich of Abilities in Motion commented: While reading the WIOA Combined State Plan, it is apparent the state is still looking to keep the partnerships they currently have, and not seeking to expand their partnerships. Currently, if a person with a disability comes to a local Careerlink and discloses a disability, they are automatically referred to Office of Vocational Rehabilitation (OVR). Many times, the person referred is denied OVR services because they do not meet the requirements for Oder of Selection. This creates a vicious circle where the person with a disability falls through the cracks of these systems. This new plan continues with the same concept when Careerlinks and other partners are missing two valuable resources that can help a person with a disability: Centers for Independent Living (CIL), and also Employment Networks. CILs offer a plethora of learning opportunities for people with disabilities. They offer four core services (information and referral, advocacy, peer counseling, and independent living skills training). CILs can help people with disabilities overcome barriers that are preventing them from focusing on employment (transportation, insurance, etc.) this will allow OVR counselors to focus on career related needs. CILs can also help those who do not qualify for OVR services. Employment Networks under the Ticket to Work Program can also help. Employment Networks were created to give people with disabilities on Social Security benefits more options. Many Employment Networks assist individuals who don’t qualify for OVR services. There are many individuals with disabilities who do not meet the specifications for Order of Selection. Employment Networks can be another resource available to the partnerships the plan discusses. Employment Networks can also offer a “hand off” opportunity for OVR clients receiving Social Security Benefits. This means individuals who have successful case closure can be referred to Employment Networks to continue assisting them with their employment goals and continue working towards self-sufficiency. The state has many great opportunities to help people obtain work and/or return to work. As with anything, there is always room for improvement. With the Employment First Initiative, it is more apparent now than ever to have as many resources in place to help those with disabilities seeking competitive and integrated employment. Response: We appreciate the comment in support of the plan and acknowledge the valuable resources available for individuals with a disability from partners such as Centers for Independent Living (CILs) and Employment Networks. AHEDD offered multiple comments to include: Thank you for the opportunity to submit our thoughts and suggestions regarding the State Plan. This is a great first draft and embodies significant changes that are a positive for people within our state and nation! Public Comments Page 1 Response: We appreciate the overall sentiment. There is no mention of PA Business Leadership Network (PA BLN) while there are many programs and partnerships mentioned by name and many references to OVR’s commitment to business partners. OVR’s SPOC model is highlighted and other resources and collaborations are only alluded to on page 140. In response to the business community’s needs for a diverse set of qualified workers to fill its labor needs, meet its compliance requirements, and respond effectively to the needs of its diverse customers, AHEDD began coordinating a statewide business initiative, The Pennsylvania Business Leadership Network (PA BLN), in 2000. The PA BLN is part of a national initiative which began in 1994 and that includes approximately 50 BLN affiliates throughout the country. The national effort is now led by the USBLN (http://usbln.org/ ) which has the support of a number of corporate partners. The PA BLN describes itself an employer-driven program designed for business leaders to promote hiring practices that enable qualified people with disabilities to enter and succeed in the workplace. The key approach of this network is to provide companies with a ‘business friendly’ approach that focuses mostly on getting employers to talk with each other, peer-to- peer. As described in the HOW TO GUIDE ( http://www.portal.state.pa.us/portal/server.pt?open=18&objID=1376016&mode=2&externalur l=http://www.padesummit.org) that was produced with federal funds from the Centers for Medicare and Medicaid Services (CMS) Medicaid Infrastructure Grant (CFDA # 93.768), the PA BLN offers business a private and alternate path for learning about, starting, and expanding their strategies to increase the diversity and inclusion in both their workplace and marketplace. As a statewide initiative of a private, non-profit organization, the PA BLN can demystify the available resources, both public and private, in the Commonwealth and offer businesses ideas and connections for flexible and creative solutions that meet the varied logistics and nuances found in each industry/workplace. The PA BLN specifically offers employers: access to pertinent disability related information; a network of employers who can share experiences and best practices; exposure to qualified job applicants with disabilities; training on disability related resources, strategies, etiquette, and more; and opportunities for positive public relations to promote a “disability friendly” status. Response: We accept the comment and have amended the plan to include mention of the Pennsylvania Business Leadership Network on page 139. Goal 1.5: The commonwealth will mainstream job seekers with barriers to employment to the maximum extent possible….by ensuring necessary supportive services are in place and coordinated across agencies, so that those individuals with the most significant barriers to employment are successful….. How will the system identify people with disabilities and ensure they are served throughout? During the WIA era, there was a lot of criticism directed towards the One Stop System in PA and nationwide for ineffective efforts at serving persons with disabilities. The frequent complaint was that the one stop system, if it served a person with a disability, saw the state vocational rehabilitation agency as the exclusive option. There were also Public Comments Page 2 concerns with the inability of this system to track how many people with disabilities it actually served. A review of the state plan suggests that this will continue with WIOA with a heavy handed reliance on the PA OVR. Response: WIOA strengthens the foundation for the establishment of a comprehensive, accessible, and high-quality workforce development system that serves all individuals in need of education and employment services, including individuals with disabilities, and employers in a manner that is customer-focused and that supports an integrated service delivery model. In addition to the indicators of performance for activities provided by the core programs, Title IV of the Rehab Act Section 414 State Plan requires the number of individuals referred to State VR programs (OVR) by one-stop operators (as defined in section 3 of WIOA), and the number of individuals referred to such one-stop operators by State VR programs. The CWDS tracking and reporting of individuals referred and served by these programs will help identify areas of need for improved collaboration to adequately serve individuals with disabilities through the PA CareerLink® system. With over 725,000 working aged adults and 75,000 youth with disabilities, PA has an ever growing caseload of residents receiving disability related benefits from the Social Security Administration (SSA). Since 2001, SSA has operated two distinct programs in every state to promote and facilitate employment and increased earnings among individuals with disabilities who are otherwise dependent on government benefits. These programs include Work Incentives Planning Assistance (WIPA) and Ticket to Work. It is unfortunate that the PA WIOA state plan has not identified SSA beneficiaries as a targeted demographic group, reflecting a perspective that this group of people do not warrant consideration within the PA workforce system. • Furthermore, the plan’s lack of inclusion of SSA’s WIPA and Ticket to Work initiatives is a lost opportunity to harness technical expertise and commitment of organizations to serve this population. Giving people options for how to get service and helping them to understand how work will impact their benefits are often key elements in the decision to work. We need this expertise included to incentivize employment for people with disabilities or they may not attempt work or remain in the workplace at their fullest potential. Response: We appreciate the comment. The commonwealth will continue to focus efforts on those with barriers to employment, including individuals with disabilities as defined in WIOA. Additionally, the Department of Human Services (DHS) agrees that people with a disability receiving DHS-funded