RSA-227 for FY-2025: Submission #7

2. Describe the systemic activities conducted by CAP during the fiscal year and its impact on other agency's policies or practices. 1. DRSC testified at the South Carolina House of Representatives Government Efficiency and Legislative Oversight Committee on March 19, 2025, and provided written Testimony on the South Carolina Vocational Rehabilitation Department (SCVRD). DRSC highlighted concerns that clients had shared with them regarding barriers to the application and eligibility process, bureaucratic red tape for post-secondary education, failure to recognize informed choice of clients, and obstacles to clients with intellectual disabilities, confusion on the SCVRD’s role with transition services, and the lack of customized employment.

DRSC’s recommendations to the committee included having SCVRD update its Consumer Service Policies to prioritize transparency, clarity, and accountability, thereby promoting better individual outcomes, requesting updates from SCVRD regarding completing and implementing all Consumer Service policies, and requesting that the South Carolina Legislative Audit Council (LAC) conduct an independent and objective audit of SCVRD, since there is no record of an audit of this department. DRSC recommended that an independent and objective audit address the application process and eligibility for services, client-informed choices in developing an employment plan, services for individuals with intellectual disabilities, autism spectrum disorder, and traumatic brain injury, and SCVRD’s plan to implement customized employment and expand its role in transition services for students with disabilities.

2. CAP has been advocating for the revision of SCVRD Consumer Service Policies, which have long failed to comply with the Rehabilitation Act, WIOA amendments, and VR regulations. In 2022, RSA placed SCVRD under a Corrective Action Plan. RSA determined that SCVRD lacked adequate policies to ensure that VR services complied with statutory and regulatory requirements. The Corrective Action Plan required SCVRD to develop and maintain written policies covering the nature and scope of each VR service, as well as the criteria for providing each service.

Problems remain. Although a considerable number of Consumer Service Policies were revised and reviewed by RSA and CAP during FY 2024-25, a significant number remain noncompliant. There is no full, complete set of policies. In addition, policies are not consistently implemented, and staff do not appear to have adequate training. Moreover, determinations on eligibility and provision of specific services are at times severely delayed, such that consumers may give up in their search for rehabilitation support. The role of the SCVRD Ombudsman remains problematic; he does not act to resolve disputes in a neutral setting but, instead, serves more as a gatekeeper and decision-maker, usurping the roles of other VR staff. The Ombudsman is compromised by his dual position as Quality Assurance Manager. CAP continued to address each of these failings during FY 2024-25.

Recommendations for SCVRD to consider in strategic planning, through at least 2025, included actions to:

i. Educate potential consumers and their families about SCVRD’s mission and services.
ii. Determine eligibility as quickly as possible so that progress can be made sooner.
iii. Provide timely services and seek to minimize attrition after eligibility, before and after IPE development.
iv. Ensure services are provided by well-trained staff who implement best practices for helping consumers obtain and maintain competitive integrated employment.
v. Provide services more consistently across South Carolina, particularly in rural areas.
vi. Offer occupational, vocational, and customized training in work and job training centers, including training that result in industry-recognized credentials, to prepare consumers for jobs that are available in their local communities and which put them on career paths.
vii. Support students with disabilities to the extent possible in pursuing postsecondary education, including undergraduate and graduate school and/or trade school.
viii. Ensure that people with the most significant disabilities have timely access to Supported Employment Services provided by qualified staff.
ix. Make Customized Employment Services available to eligible consumers with the most significant disabilities through a network of qualified providers who negotiate customized job positions directly with employers based on the unique profile of the consumer.

CAP has taken various approaches to redress these needs. Through correspondence and quarterly virtual meetings with select SCVRD staff, CAP has alerted the SCVRD Commissioner, Consumer Services Director, respective VR Counselors and Area Supervisors, and the Ombudsman’s office.

Systemic progress has been slow, so during FY 2024-25, CAP regrouped and will explore alternative ways to address this matter this fiscal year.

3. South Carolina Transition Resource: Based on comments from people with disabilities and families requesting more resources on transition services, DRSC created an interactive guide on their website, called A South Carolina Transition Resource. The purpose of this guide is to prepare young people with disabilities for life after school. The guide includes information on finding a job, attending college or technical school, and living as independently as possible.

The outcome of this guide is that more people with disabilities will understand that the services and resources available during transition can help them reach their life goals after school and use this guide to help navigate the priorities important to them, as they prepare for adulthood and independence.
Source : https://www.disabilityrightssc.org/resource/life-after-school/.

4. VR Transition Video: DRSC participated with other CAPs to create a short video called “What Does the Client Assistance Program Do?” that can be found at: https://www.youtube.com/watch?v=W4sT1oP0e10. This resource was developed to help inform individuals with disabilities about how CAP can support them and to provide examples of the types of assistance CAP can provide.


5. Employment Services Project: Community input and DRSC work raised concerns regarding whether individuals with intellectual disabilities and autism spectrum disorder are receiving appropriate employment/career preparation services to find and engage in competitive integrated employment (including individuals receiving Social Security disability benefits). DRSC began a systemic project to investigate employment preparation services for these populations, determine their efficacy, and identify any barriers to achieving competitive integrated employment. DRSC reviewed intakes and cases for systemic concerns. Research was conducted on vocational rehabilitation and Medicaid waivers that support work goals. DRSC reviewed SC’s WIOA Combined State Plan and comments on the current plan as well as SC Legislative Audit Council’s audits of the SC Department of Disabilities and Special Needs (now known as the Office of Intellectual and Developmental Disabilities). We have decided to focus this project on individuals receiving waiver services and plan to continue this project in the upcoming fiscal year.

6. SC Disability Employment Coalition: DRSC is a member of the SC Disability Employment Coalition (SCDEC). SCDEC is a coalition of state agencies, disability advocacy organizations, and educators, including representation from the SC Vocational Rehabilitation Department, the SC Commission for the Blind, and Able SC. The coalition’s goal is to address employment barriers for people with disabilities. SCDEC holds quarterly meetings that DRSC regularly attends to share resources, updates, and information on services and support for individuals with disabilities in South Carolina.