1. Number of non-litigation systemic activities not involving individual representation that resulted in the change of one or more policy or practice of an agency.
2
2. Describe the systemic activities conducted by CAP during the fiscal year and its impact on other agency's policies or practices.
Psychiatric Residential Treatment Facilities
At the beginning of FY25, the DLC’s CAP team started collaborating with the Abuse and Neglect (AN) team in the agency. The CAP and AN teams started visiting Psychiatric Residential Treatment Facilities (PRTFs) across the state. The psychiatric residential treatment facilities house youth who are working towards treatment that addresses their mental health. The CAP team's purpose was to visit and talk to the youth residing in these facilities about employment, CAP and the VR services available to them. CAP also wanted to get a better understanding of VR’s role and/or participation at the PRTFs across the state.
During the visits, CAP discovered that youth in PRTFs are gravely lacking employment skills and services. All the youth that CAP was able to talk to had very reasonable and obtainable job goals in mind. However, they have limited resources inside the PRTFs. Many of the PRTFs have limited training and support related to employment skills. Therapists in one facility provide the youth with some employment resources when they discharge. However, when CAP connected with the staff CAP was informed that the therapists were not familiar with VR services. CAP provided information regarding VR services and explained the eligibility process, Individualized Plans for Employment, Pre-ETS, etc to each individual CAP connected with and to the staff in the facility. Both youth and staff were very receptive of the information being provided. CAP was able to provide information on the other VR agencies across the states to the youth, since many of them go back home to a different state when they complete their treatment.
After visiting a few of the PRTFs, it was clear that VR was not visiting these facilities and connecting with youth who are experiencing mental health challenges. CAP kept track of the information collected on youth, staff, and the facilities and was able to provide VR with the information collected during these visits. During a quarterly meeting with USOR assistant director, regional directors, and training coordinator CAP requested that VR have a presence at these facilities and start providing at least pre-ETS to the youth.
Below is the email that CAP sent to VR after our first initial visits to two facilities:
“The CAP team has visited a few PRTFs and has found that most of the youth in these facilities would greatly benefit from VR services. Staff in these facilities along with the youth have all been really interested in how VR may be able to help with employment services and reintegrating back into the community once they are finished with their treatment (the team did not talk to a single staff/youth that already knew about VR unfortunately). We found that a lot of these youth don't really have a plan once they are discharged from the facilities, but a lot of them are very interested in employment.
We only had the chance to talk to a small group of youth at two facilities:
Copper Hills Youth Center had 120 residents at the time of our visit. We talked to 20 residents that were very interested in VR services. Below are the ages of some of the residents that we think would be ready for a VR counselor and those who we think would greatly benefit from pre-ETS.
Ready for a VR counselor and longer-term IPE:
5 - (17, 17, 17, 17, 17)
Ready for pre-ETS:
15 - (15,16, 13, 15, 14, 16, 16, 16, 14, 15, 14, 12, 13, 15, 16)
Provo Canyon School had 146 residents at the time of our visit. We talked to 11 residents that were very interested in VR services. Below are the ages of some of the residents that again we think would be ready for a VR counselor as they had graduated from school already or are getting ready to graduate, but don't really know what's next for them. The younger youth would benefit more from pre-ETS to get them thinking about different types of employment opportunities, preparing them for workplace readiness skills, etc.
Ready for a VR counselor and longer-term IPE:
5 - (17, 17, 17, 17, 17)
Ready for pre-ETS:
6 - (16, 14, 15, 13, 16, 14)
*CAP is aware that youth must be at least 14 years old for them to access VR services. We did give those 13 and under information on VR to get them thinking about employment/careers and to let them know of what is available as they get older, but we did let them know they have to be at least 14 years old to be able to work with VR.”
During our quarterly meeting with VR, they were accepting of the information being provided and informed CAP that they would start making contact with some of the facilities we provided contact information to. CAP has asked for regular updates and has confirmed that VR has made contact with at least one facility and provided an overview of the services they provide. While CAP believes we have made some progress with VR, we would like to see greater effort from VR reaching and working with the youth in a more individualized and hands on level at these facilities. CAP’s next goal is to make this request in a more formal manner to VR to emphasize the importance and impact their services and presence can have on the youth. CAP believes that our systemic efforts in reaching youth in PRTFs allowed us to identify a very important need. CAP hopes that as we enter FY26 we can provide VR with a formal letter and additional data to request that they visit and work with the youth that need their services the most.
Atherton Community Treatment Center
During FY25, a case worker from a community treatment center contacted CAP, because their clients were also VR clients. The case worker informed CAP that VR was refusing to provide Job coaches for their clients stating that they can’t find coaches willing to work with their population. She also stated that their clients have a serious mental health illness and need more assistance than most to obtain a job. CAP was able to discuss this issue with Atherton and decided that we would request VR records. CAP received VR records from 19 VR clients from two different VR districts.
While CAP reviewed VR records, it was discovered that not only was VR not providing job coaches, but there were also additional concerns that stood out to us. CAP brought up these issues to VR during a quarterly meeting with the director, regional director, and their training coordinator. Below are the concerns that CAP raised:
-IPE Job goals are not reflecting client needs, interests, capabilities, etc. USOR policy states that, "The VR Counselor must conduct a Comprehensive Assessment of Rehabilitation Needs for each eligible individual in a timely manner following eligibility. The purpose of the assessment is to determine the specific employment outcome and the nature and scope of vocational rehabilitation services to be included in the IPE." In reviewing records, it appears VR counselors aren't really engaging clients during plan development and many of the job goals listed are just production workers, janitorial, and cooks.
-There was one client in the South Jordan office that did identify IT as a long-term career goal for himself. This goal was listed in the plan, but it doesn't look like the counselor is assisting the client work towards this goal. No training has been identified or discussed, and the client is applying at retail stores or fast-food restaurants at this time.
-While reviewing eligibility letters, it looks like a significant number (most) of the clients have a serious mental health illness or multiple. We were wondering about their disability category classification as they were all found eligible on category 2, significantly disabled. Can you folks touch on why they don't fall under category 1 and maybe provide examples to help us understand.
-Through conversations with Atherton, they let us know that they have requested job coaches for their clients to the counselors. However, counselors have stated job coaches do not want to work with this population.
CAP and VR had a lengthy discussion about the items we were concerned about. VR did let CAP know that the VR counselors would be receiving additional training on providing more individualized services to Atherton clients. However, an item that is still part of ongoing discussions with VR and Atherton is eligibility and disability classification now that our state’s VR agency has implemented an Order of Selection. All clients that CAP reviewed records on, were found eligible on category 2 (significant disability) despite having a serious mental health diagnosis and a number of functional capacity limitations. Additionally, both CAP and Atherton have informed VR that many of these clients who were formerly incarcerated and starting to reintegrate into the community have huge barriers when it comes to advocating for themselves. VR has assured CAP that they will be doing a better job by asking questions and assisting new clients from Atherton during their eligibility. CAP has informed Atherton to let us know if VR continues to place clients under category 2 without first completing a comprehensive assessment. Lastly, CAP has begun to work individually with an Atherton client, this will allow the client to receive appropriate services and will allow us to address any more systemic issues that may arise.