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RSA-227 for FY-2025: Submission #25

Colorado
09/30/2025
General Information
Designated Agency Identification
Disability Law Colorado
1580 N. Logan, Suite 600
Denver
CO
80203
https://disabilitylawco.org
7202418727
Operating Agency (if different from Designated Agency)
Additional Information
Kelly McCullough
Gina Viola Brown
7202418727
gbrown@disabilitylawco.org
Part I. Non-case Services
A. Information and Referral Services (I&R)
7
0
0
0
3
10
20
B. Training Activities
6
293
a. CAP training for new DVR counselors
The CAP Advocate and a Disability Rights Attorney recorded a comprehensive CAP training for new DVR counselors. The training explains what CAP is, the services we provide, the importance of involving CAP early in the vocational rehabilitation process, and how counselors can contact CAP. The fully captioned and ASL-interpreted video was completed and delivered to the Colorado Division of Vocational Rehabilitation on February 24, 2025. DVR now includes this recording in its onboarding curriculum.
Approximately 15 new DVR counselors are expected to view the training each year.

b. Center for Independent Living Training Grand Junction

On May 19, 2025, the CAP Advocate delivered a virtual presentation to the Center for Independent Living in Grand Junction. The goal of the training was to strengthen CIL staff understanding of CAP and DLC services so they can accurately inform their customers and make appropriate referrals. The CAP Advocate explained the role of CAP, how referrals can be made, and how CIL staff can request technical assistance when supporting individuals involved in the vocational rehabilitation process.
Number of CIL staff attending this presentation: 8

c. Center for Independent Living Training Durango
On May 19, 2025, the CAP Advocate delivered a virtual presentation to the Center for Independent Living in Durango. The goal of the training was to strengthen CIL staff understanding of CAP and DLC services so they can accurately inform their customers and make appropriate referrals. The CAP Advocate explained the role of CAP, how referrals can be made, and how CIL staff can request technical assistance when supporting individuals involved in the vocational rehabilitation process.
Number of CIL staff attending this presentation: 8

d. Colorado Assistive Technology Coalition
On October 22, 2024, the CAP Advocate presented on CAP for a state assistive technology committee. The CAP advocate provided information about what CAP is, how we assist individuals going through DVR, and how to contact CAP.
Number of coalition members attending this training: 13

e. Division of Vocational Rehabilitation Training - Denver
On May 29, 2025, the CAP Advocate provided a training to DVR counselors in Denver. DVR staff had reported difficulties explaining the Client Assistance Program to clients, which resulted in individuals learning about their rights late in the VR process or receiving CAP contact information without understanding CAP’s role. Counselors were also unfamiliar with the broader services offered by Disability Law Colorado or how to make referrals when clients experienced disability-related discrimination.
The training clarified the purpose and function of CAP, how and when to involve CAP in the VR process, and the full range of DLC services available to DVR clients. Following the presentation, the CAP Advocate sent additional written materials to DVR for distribution to counselors and supervisors, including information on CAP, employment-related advocacy, and referral procedures.

243 DVR staff attended this training

f. Higher Ed Training for Division of Vocational Rehabilitation
On August 6, 2025, An attorney from the P&A provided a training for Division of Vocational Rehabilitation Counselors in rural northeast Colorado about rights in higher education as compared to K-12 settings. This will enable the counselors to better assist their clients who have concerns with programs of higher education.
6 DVR Counselors attended this training.
C. Agency Outreach
We collaborate with and conduct targeted outreach to a wide range of community partners to identify and serve individuals who are unserved, underserved, and members of minority communities. These partners include the Colorado Department of Education; The Arc of Colorado and local Arc chapters statewide; Centers for Independent Living; Southern Ute Vocational Rehabilitation; the Division of Vocational Rehabilitation; the Brain Injury Alliance; PEAK Parent Training Center; the Colorado Developmental Disabilities Council; the University Centers for Excellence in Developmental Disabilities; the Colorado Assistive Technology Project; Denver Fair Housing; the Colorado Poverty Law Project; the Denver Metro Parent Center; the Civil Rights Education and Enforcement Center; the Colorado Cross-Disability Coalition; and the Office of Employment First. Through these relationships, we request referrals, share materials, and coordinate efforts to ensure that individuals who face barriers to services are able to access our programs.
To promote equitable access, the majority of our resource materials are provided in both English and Spanish, ensuring that consumers in the Latino community receive the same information and supports. We have expanded the amount of Spanish-language content on our website to improve accessibility, and we administer consumer surveys year-round in both English and Spanish to help guide and assess our work. We have a bilingual paralegal on staff to support the development of Spanish-language materials and to provide interpretation services during client interactions.
In addition, we have conducted trainings with two of the most rural Centers for Independent Living in the state to better reach individuals in geographically isolated communities who may have limited access to advocacy resources.
D. Information Disseminated To The Public By Your Agency
0
0
0
10200
4
129739
Social Media – The DLC Facebook account received an average of approximately 9,571 hits per month for an annual total of 114,853. The DLC LinkedIn account received 1,701 hits total. The DLC Instagram account received 13,185 profile views for FY25.
E. Information Disseminated About Your Agency By External Media Coverage
104 Radio or TV appearances by Disability Law Colorado staff. 53 articles about the P&A or its work in external mass media.
Part II. Individual Case Services
A. Individuals served
12
64
76
4
13
B. Problem areas
9
25
35
1
0
5
0
3
0
0
C. Intervention Strategies for closed cases
50
0
9
0
8
0
0
67
D. Reasons for closing individuals' case files
0
47
0
5
3
10
2
0
0
0
0
0
We entered zero in D12
E. Results achieved for individuals
16
2
0
0
10
7
4
10
0
18
The 18 case files that are listed in other had a variety of results. For most of these cases, the client was provided additional information about DVR. In a few of these cases, the client did not follow-up or stopped responding to communications from the CAP program.
Part III. Program Data
A. Age
2
3
30
37
4
76
B. Gender
50
24
0
2
76
C. Race/ethnicity of Individuals Served
6
1
2
9
0
47
0
11
D. Primary disabling condition of individuals served
3
4
0
0
1
0
13
2
1
0
0
0
7
1
0
0
0
0
1
4
20
1
0
2
2
7
0
0
0
3
1
0
1
2
76
E. Types of Individuals Served
16
1
57
4
0
0
Part IV. Systemic Activities and Litigation
A. Non-Litigation Systemic Activities
3
a. Centers for Independent Living – Inform about CAP and Grievance Process

While working on two to three individual Client Assistance Program (CAP) cases related to Centers for Independent Living (CIL), we noticed that clients were not properly informed of CAP services, and CAP was being referenced improperly as the last step in the grievance process of the CIL. By the time clients came to CAP for help, they were angry because they did not know that CAP could assist them throughout the CIL’s grievance process, and they thought that CAP was the final decision maker. After talking to multiple CIL Directors, CAP requested each CIL’s client grievance process and the methods they utilize to inform their customers of the availability of CAP. Most of the CILs did not understand the role of the CAP, the services provided by CAP and that CAP could be involved at any level in the client grievance process. CAP confirmed that several other CILs were presenting CAP as the last step in the grievance process and implying that CAP was the final decision maker. This information was shared with the state manager for independent living programs, and he invited the CAP to come to the state CIL directors meeting to present. CAP provided a short presentation shared draft/sample language that each CIL could include in their grievance procedures, and notification of CAP services. CAP was also invited to present at four of the nine CIL’s staff meetings to better explain CAP and services provided by Disability Law Colorado.

b. Self-Employment

Describe each non-litigation systemic activity completed during the fiscal year, including

CAP staff have been exploring, researching, and gathering materials to work on systemic issues with DVR on Self-Employment. DVR has some serious issues related to Self-Employment services. Vendors complain there are no timeframes for SERT team meetings and decisions. For clients receiving services, proof of concepts/feasibility are being denied without negotiation or allowing people to add or correct information. DVR has been using outside consultants to deny first level plans not the business plan. CAP staff have requested DVR’s training manual for counselors providing Self-Employment. DVR policies and funding levels are extremely low compared to other states.
CAP staff have met at least twice with the DVR Business Relations Unit Manager that oversees Self-Employment. CAP staff shared concerns at quarterly meetings with DVR Administrators for the last year including long-delays and repeated requests by the Self-Employment Rehabilitation Team (SERT) for additional information that had already been provided or new information that is not part of the process, which delays approval of the client’s business plan and employment. CAP staff discussed the self-employment issues of delays and inconsistency of the SERT process with the State Rehabilitation Council (SRC). CAP staff filed a Colorado Open Records Act (CORA) request to gather more information supporting concerns clients are experiencing related to self-employment.

As a result of these CAP staff actions, DVR is considering a focus group to hear about what is not working, what is working and recommendations for change. DVR is also working with a DIF grant and having their policies reviewed. Finally, DVR is considering additional training for all DVR counselors.
SERT started sending decisions directly to the client and the DVR counselor at the same time to cut down on delays because of high caseloads of DVR counselor and steps in the SERT/self-employment process. CAP staff have not seen additional benefits to individuals with disabilities but more people within DVR are aware of issues related to those seeking self-employment. DVR reviewed their own policy and determined in one situation they were not requiring certain cases to be reviewed by SERT.


c. Quarterly meetings with DVR

Over the past year we have continued to meet quarterly with DVR administration to discuss systemic issues identified by CAP and DLC. Through these meetings we have continued to raise issues surrounding counselor turnover, the lack of resources for self-employed individuals, and the lack of DVR vendors in rural areas.

CAP personnel met with DVR Executive Director and Field Service Director to share concerns with DVR Services and to hear updates from DVR. CAP was referred to talk with other DVR staff about self-employment issues, failure to provided written decisions for denial of services, requests to update CAP information in DVR client handbooks, Eligibility Determination, IPEs, and closure documents. CAP staff recommended that CAP not be listed last in the appeals process because clients don’t understand they can request CAP assistance at any level of the appeals process. CAP raised concerns with the high turnover rate of DVR counselors. CAP staff conveyed concerns that the lack of vendors in rural areas meant clients did not have choices.

DVR is focused on their new case management system, so no corrections were going to be made until they get their new case Management system, called RIVR, implemented. As a result of these CAP activities, CAP staff were invited to an all-DVR staff meeting to present on CAP to help them all better understand what CAP does and their responsibilities to inform clients of CAP services and how to contact CAP for assistance. CAP staff provided DVR staff a CAP flyer in English and Spanish to share with their clients. CAP staff also shared concerns of clients with multiple counselors and the negative impact on client’s continuum of services and progress of reaching their employment goals

These changes benefited individuals with disabilities in the following ways:
1. More DVR counselors have contacted CAP or DLC for assist their clients
2. DVR has experienced a lower rate of counselor turnover
3. We are still waiting for DVR to correct the CAP information in their system
4. DVR agreed to a focus group of past and current clients seeking self-employment, with vendors and advocates as well

B. Litigation
0
0
0
We do not currently have any on-going or completed systemic litigation activities.
Part V. Agency Information
A. Designated Agency
External-other nonprofit agency
Disability Law Colorado
No
B. Staff Employed
Staff Employed during FY24-25 and working on the CAP Program or doing administrative activities supporting CAP work:
Brieno, Esther Operations Manager 9%
Brown, Gina Viola Director of Mission Support 8%
Craig, Nicole Operations Coordinator 8%

Erickson, Kim CAP Advocate 70%
Garberding, Angie Senior Intake and Self-Advocacy Specialist 6%
Harvey, Emily Co-Legal Director 4%
Hecht, Morgan Disability Rights Attorney 4%
Hostetler, Molly Senior Disability Rights Attorney 4%
Johnson, Jack Public Policy Liaison 1%
McCullough, Kelly Co-Legal Director 9%
Mook, Bob Development Manager 3%
Ortiz, Felix Communications Manager 5%
Petrie, Gentrice Intake and Self-Advocacy Specialist 8%
Postlewaite, Tim Intake and Self-Advocacy Specialist 20%
Rios, Pamela Paralegal 10%
Roberts, Kassidy Disability Rights Attorney 4%
Romanoff, Andrew Executive Director 7%
Part VI. Case Examples
Case Examples
1.

An individual with multiple disabilities contacted CAP regarding delays and obstacles from her Division of Vocational Rehabilitation (DVR) counselor in pursuing her vocational goal. The client, who could not leave her home, initially lacked the equipment to take a required assessment remotely. DVR refused to provide accommodations, insisting she test in person. Through CAP advocacy, DVR approved remote testing accommodations.
DVR continued to delay approval of her Individualized Plan for Employment (IPE), repeatedly requesting proof of remote job opportunities despite the client submitting multiple postings. While delays persisted, CAP helped the client access support from her local workforce center and Center for Independent Living, enabling her to take foundational courses and earn As.
Ultimately, CAP advocacy secured DVR approval of her IPE, including educational and support services, allowing the client to continue pursuing her degree and vocational goals in her chosen field.

2.
An individual with a disability attending college contacted the Client Assistance Program (CAP) at Disability Law Colorado with concerns regarding her Division of Vocational Rehabilitation (DVR) counselor. The counselor had terminated the client’s mileage and tuition assistance for the upcoming semester, despite the student maintaining a high GPA. No explanation was provided for the termination. The client, who lives in a rural area, relies on this assistance to commute a significant distance to attend college.
CAP staff represented the student through the first two levels of informal appeal. At the second level, DVR agreed to reinstate the assistance and reimburse the client for expenses incurred due to the wrongful termination. Without CAP’s intervention, the student may have been forced to withdraw from college due to financial barriers.

3.
An individual with a disability engaged in DVR’s self-employment services contacted CAP after her counselor denied her advancement based on a vendor report. The counselor failed to provide a written decision, explain appeal rights, or inform her of CAP services, and pressured her to accept a different goal or close the case.
CAP’s review found DVR had not followed its own procedures, including the use of incorrect criteria in the vendor report, which denied the client’s plan without allowing updates as required.
CAP represented the client in an informal appeal, requesting that DVR allow her to update her plan, assign a new counselor, provide staff training on written decisions, appeal rights, and CAP services.
As a result, DVR assigned the client a new counselor, allowed her to update her plan, and CAP informed DVR administration of the systemic issues.
Certification
Reports are to be submitted to RSA within 90 days after the end of the fiscal year covered by this report. Please be reminded that you can enter data directly into the RSA website via the internet. Information on transmittal of the form is found on pages 19 and 20 of the reporting instructions.
Name and Title of Authorized Certifying Official
I agree to submit this form by electronic means. By signing this form electronically, I certify under penalty of perjury that my answers are correct and complete to the best of my knowledge. I understand that an electronic signature has the same legal meaning and can be enforced in the same way as a written signature.
Gina Viola Brown
Director of Mission Support
Yes
2025-12-03
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