RSA-227 for FY-2025: Submission #32

2. Describe the systemic activities conducted by CAP during the fiscal year and its impact on other agency's policies or practices. 1) Bureau of Education and Services for the Blind (BESB) State Rehabilitation Council (SRC): During the 2025 fiscal year, program staff participated in the Vocational Rehabilitation (VR) Policy Manual work group, whose goal is to update and revise the manual so that it better aligns with regulations of the Rehabilitation Act. The staff provided an updated description of the CAP services, emphasizing that our services are free and confidential. The Senior Advocate also provided input on the sections describing comparable services and benefits, post-secondary training, informed choice, limitations on the use of sub-minimum wage, and presumption of eligibility for Social Security beneficiaries. Specifically, CAP staff added language to the section on post-secondary training, asserting that the Designated State Unit (DSU) will not apply a financial means test or require cost participation as a condition for receipt of VR services for Supplemental Security Income (SSI) or Social Security Disability Insurance (SSDI) recipients. The CAP staff advocated for changes in the ‘limitations on the use of sub-minimum wage employment’ section, resulting in new details and language around informed choice and how it impacts and advances the goals of access to competitive, integrated employment (CIE) and BESB services. As a result of the CAP staff’s participation on the SRC and these changes to the policy manual, applicants and consumers with the most significant disabilities will have increased access to CIE through CT's BESB.

2) Competitive Integrated Employment for People with Intellectual and Developmental Disabilities in Connecticut: The CAP staff worked collaboratively with the CPR on the systemic issue of expanding services for individuals with more significant support needs to gain Competitive Integrated Employment (CIE). In April, the Connecticut Department of Developmental Services (DDS) and the Connecticut Bureau of Rehabilitation (BRS) published a CT Employment Systems Transformation Plan (the Plan) to expand CIE for youth between the ages of 14-26 and adults with intellectual and developmental disabilities (IDD) in Connecticut. The Plan sets forth agency action steps to provide individuals with opportunities to learn about, secure, and maintain CIE and includes a timeline and benchmarks for implementation. The Plan was developed based on an August 2024 agreement between the State agencies, CAP staff, and CPR. Despite youth between the ages of 14-26 being a primary audience for the Plan, the CT State Department of Education (CSDE) was only peripherally involved in negotiations leading up to the agreement and declined to participate altogether in the development of the Plan. CAP staff and CPR meet quarterly with DDS and BRS to receive updates on the status of their progress towards the plan objectives. The parties identify focus areas for each quarter and convene smaller "working group" meetings as needed to receive updates and provide input on those topics. CAP staff continue to monitor the implementation and progress towards the plan's objectives.

The transformation plan is now publicly available so that consumers with IDD, including those with the most significant disabilities, are aware of what types of employment services are available to them and how to access them. The plan can be found at: https://portal.ct.gov/ads/-/media/ads-beta/brs-files/joint-cie-transformation-plan-2025---final-april-2025.pdf

As a result of the CAP’s advocacy, DDS and BRS developed new practices for consumers with the most significant disabilities such that appropriate employment services, including discovery, job exploration, job development, and ongoing, long-term job supports are available. DRCT continues to educate and advocate for individual clients pursuing CIE, helping them access employment services.


3) Connecticut Pathways to Integrated Employment (CTPIE) Community of Practice: CAP staff participated in a statewide Community of Practice (CoP) around the Connecticut Pathway to Integrated Employment (CT PIE) project, which is the result of a Disability Innovation Fund (DIF) grant focused on individuals with significant disabilities who are currently working in sub-minimum wage employment or may be at risk of placement into segregated, uncompetitive employment situations in absence of strong self-advocacy. During this fiscal year, the CT PIE program provided the CoP with updates on the grant's progress and education on topics such as Job Development and the legal definitions of CIE. The University of Maryland (UMD), which provides technical assistance for this grant, has sought to shift the group's focus from information sharing to a more authentic community-of-practice (CoP) model. They surveyed participants in the CoP to help them understand providers' needs and identified those with expertise who can contribute to the CoP. Participants expressed concern that the CoP was missing key members, including individuals enrolled in the program and VR counselors serving youth. Providers cited caseload and capacity constraints that prevented them from committing to the monthly CoP. As a result of the responses they received, UMD and the BRS decided to disband the CoP until they could determine a more effective format and include the appropriate participants. The CAP staff advocated for CT PIE to consider an alternative avenue for soliciting feedback from a broader stakeholder group (e.g., employment vendors). Program leaders from BRS and UMD agreed to meet with us to discuss DRCT’s ideas. They remain open to input from the CAP on issues of enrollment and informed choice.

As part of CT PIE, BRS has struggled to reach and recruit adults currently working in sub-minimum-wage employment which is the intent of the DIF. They acknowledge that their current policies and procedures for Career Counseling Information & Referral (CCI&R) requirements under Section 511 of the Workforce Innovation and Opportunities Act (WIOA) do not comply with the law. In past years, a 15-minute video produced by BRS was shown to individuals working in sub-minimum wage jobs. Subsequently, a ‘sign-in’ sheet was sent to BRS, from which they mailed certificates of completion to the individuals. This fiscal year, BRS shared new, proposed in-person presentation materials and outreach documents with the CAP. DRCT provided feedback and advice for revisions of the procedures, as well as information and suggestions about what the requirements might look like when implemented in practice. As a result of the CAP’s advocacy, BRS began the process of revising their procedures for CCI&R likely to result in increased access to VR services for eligible consumers.


4) Bureau of Rehabilitation Services (BRS) State Rehabilitation Council (SRC): Throughout the 2025 fiscal year, CAP staff utilized its role on the BRS SRC policy subcommittee to advocate for changes in policy and practice that would expand eligibility determination for beneficiaries with the most significant disabilities, including those with intellectual disability (ID) and Autism. Connecticut faces ongoing challenges with extensive waitlists for the Medicaid Autism Services waiver (i.e., 2,249 as of April 2025), resulting in a lack of Home and Community Based Services (HCBS), including employment services, for people who do not meet the Connecticut Department of Developmental Services (DDS) eligibility requirement of an IQ of 69 or below. This is highly problematic for anyone, not just those with autism with an IDD, but all people with an IDD with IQ scores higher than 69 seeking CIE. This service gap suggests long-term challenges for adults with IDD to not only attain CIE but challenges with having the supports in place they need to sustain CIE, beyond those provided through VR, are made available in the Medicaid program.

The CAP staff advocated for VR counselors to receive training in providing suitable, reasonable accommodations to individuals with ID and Autism, thereby better enabling them to access BRS services, and for improvements in collaboration between BRS and DDS in the provision of services to mutual clients. Specific goals of the policy sub-committee included urging BRS to adopt a universal and highly streamlined approach to determining eligibility, including presumptive eligibility for recipients of SSI or SSDI, relying heavily on person-centered rapid engagement tools to capture what an individual’s employment goals are, and how they can best be supported. As the CT DDS maintains that it is an Employment First agency, the subcommittee recommended formalizing a BRS policy to train VR counselors on the value of Employment First for All and to implement practices consistent with the principles of Employment First.

Connecticut continues to face challenges with Community Rehabilitation Provider (CRP) capacity, limiting informed choice for consumers. SRC members, including CAP staff, advised BRS to increase the number and quality of CRPs to provide dependable coverage across the state and truly afford consumers an informed choice. As of the close of this fiscal year, BRS finalized its updated policy manual without adopting these policy recommendations and has not provided feedback to the SRC about its reasoning.


5) State Advisory Council on Special Education (SAC): CAP staff served as a member on the State Advisory Council for Special Education (SAC) and, as such, educated the CT State Department of Education (CSDE) and SAC members on various topics and issues concerning students with disabilities in CT, including the impacts of coordination between BRS and local school districts on the delivery of comprehensive transition services and supports, and other systemic concerns. CAP staff continued to advocate for implementing education for parents and students on decision-making alternatives, including Supported Decision Making (SDM) for high school age youth transitioning to adulthood (transition-age youth). In their role on the SAC, CAP staff worked to educate legislators on the SAC's work, keeping them better informed of the issues and challenges within special education in CT. CAP staff advised the CSDE on matters essential to improving conditions for students with disabilities. Specific issues covered included overuse of exclusionary discipline, restraint and seclusion by school districts, and insufficient oversight and monitoring by the CSDE to hold schools accountable for Least Restrictive Environments and setting Measurable Post-secondary Goals. All of these factors influence social-emotional learning and transition outcomes for youth, affecting the degree to which youth and young adults pursue career pathways and attain CIE.