Disability Coordinator Orientation Kimberly Jones, Regional Disability Coordinator

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Disability Coordinator Orientation

Kimberly Jones, Regional Disability Coordinator

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Objectives

Provide an overview of PRH Disability Program requirements

Review relevant resources and tools available to assist disability coordinators (DCs) in meeting disability-related requirements

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Disability Program Requirements

• Disability Program is now its own section in PRH, Chapter 6 – Section 6.14

Why?• To change perception of disability as only a health and

wellness program and ensure a center wide focus• To clarify and ensure consistency among existing

requirements; additional requirements have not been created

Recent Changes

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PRH 6.14 Disability Requirements

Requirement Citation

Disability Coordinators PRH 6: 6.14, R1 (a-b)

Applicant File Review ProcessPRH 6: 6.14, R2 (a-c); PRH 1: 1.4 R1-4; Exhibit 5-1 and Appendix 107

Reasonable AccommodationPRH 6: 6.14, R3 (a-c) and Appendix 605; Exhibit 5-1 and PRH 3: 3.21, R2 (g)

Introduction to Center LifePRH 6: 6.14, R4 (a-c); PRH 2: 2.2, R1 (b11); PRH 2.2, R1 (d4) and PRH 2: 2.2, R2

CIS Disability Data Collection and Accommodation Plans

PRH 6: 6.14, R5 (a-f)

Partnerships and Resources PRH 6: 6.14, R6 (a-c)

Referral Process PRH 6: 6.14, R7 (a-b)

Readily Achievable Barrier Removal PRH 6: 6.14, R8 (a-e), and Exhibit 5-2

Staff Training PRH 6: 6.14, R9; Exhibit 5-4

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Resource:

• Job Corps Disability website – Disability Coordinator

Orientation section


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Click to edit Master title stylePRH 6.14, R1 Disability Coordinators

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Requirements: PRH 6: Section 6.14, R1 (a-b)

a) Appoint DCs to oversee the program– The health and wellness manager (or a health staff designee)

and academic manager (or an academic staff designee) will function as DCs to oversee the program

– May choose to a hire full or part time DC rather than appoint DCs in academic and health

b) The roles and responsibilities of each of the DCs will be defined in an Standard Operating Procedure (SOP)

PRH 6.14, R1 Disability Coordinators

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As a DC, your responsibilities include:

• Ensuring that all required Disability Program components are implemented, monitored, and maintained in an effective manner

• Demonstrating commitment and soliciting buy-in to disability initiative (leadership)

• Delegating responsibilities

• Encouraging all staff to take ownership of the program

PRH 6.14, R1 Disability Coordinators

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Resource:

• Job Corps Disability website – Disability Coordinator

SOP


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Click to edit Master title stylePRH 6.14, R2 Applicant File Review

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Requirements: PRH 6: Section 6.14,

R2 (a-c)

a) Applicant file review process should be defined in SOP

b) Applicant files must be processed in 30 days

PRH 6.14, R2 Applicant File Review

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Requirements: PRH 6: Section 6.14, R2 (a-c)

c) All center procedures must include:• A file tracking method – Location where files are sent and logged through

final disposition• Responsibilities and roles of team members• Process for reviewing files to include denial process• Process for reasonable accommodation• Process for withdrawals• Timeframe to complete the process• Storage, transmission and maintenance of the file (Appendix 607)

* Note these requirements are also outlined in (PRH 1:1.4 R1-4 and Appendix 107)


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Resources:• Webinar – Center Responsibilities in the

Applicant File Review Process (Administrative Process)

• Webinar – Center Responsibilities in the Applicant File Review Process (Health

Care Needs/Direct Threat)


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Click to edit Master title stylePRH 6.14, R3 Reasonable Accommodation

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Requirements: PRH 6: Section 6.14, R3 (a-c) and Appendix

605

a) Defined in an SOP (PRH 5: Exhibit 5-1) a process:− for applicants/students to request and receive reasonable

accommodations (RA) and

− to ensure applicant/students who request accommodations and/or provide documentation engage in the interactive process to consider/determine functional limitations

PRH 6.14, R3 Reasonable Accommodation

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Request

Documentation

Reviewing a request

Evaluating a request

Denying a request

Developing an

accommodation plan

Notification

Determining accommodation

effectiveness

Recordkeeping

Request

Determination of need

Ensuring appropriate documentation

Reviewing a request

Determining reasonableness

Entering the accommodation plan

Notification/Viewing the plan

Documenting the process

Maintain the accommodation file

Storing accommodation and

disability documentation

Process Then Process Now

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Requirements: PRH 6: Section 6.14, R3 (a-c) and Appendix

605

b) The DCs will coordinate the center’s reasonable accommodation process

c) During Career Transition Readiness all students will receive information about workers rights and responsibilities including reasonable accommodation in the workplace (3.21, R2 (g))


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Resources: • PRH – Appendix 605 Job Corps Reasonable

Accommodation Guidelines

• Webinar – Reasonable Accommodation Process

• Job Corps Disability website – Reasonable accommodation section

• Job Corps Disability website – The RAC Guide


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Resources: Job Corps Disability website – Tools for Staff:

Career Transition Counselors


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Click to edit Master title stylePRH 6.14, R4 Introduction to Center Life

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Requirements: PRH 6 Section 6.14, R4 (a-c)

a) Provide new students with information leading to an understanding of opportunities and benefit available with the Disability Program (PRH 2: 2.2, R1 (b11))

b) Provide a variety of opportunities to meet and interact with the DCs (PRH 2.2, R1 (d4))

PRH 6.14, R4 Introduction to Center Life

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Requirements: PRH 6:

Section 6.14, R4 (a-c)

c) The student handbook will include information about the Disability Program (PRH 2: Section 2.2, R2)


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Resources: • Brochure – Reasonable

Accommodation Brochure available on the Job Corps Disability website can be customized for your center

• Webinar – Disability Sensitivity Inclusive Environments


Sylvia Domagalski, RNDallas Region Disability CoordinatorJuly 2011

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Resources: • Job Corps Disability

website – DC pictures with name and titles

• Job Corps Disability website – Sample student handbook language that can be customized for your center


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Click to edit Master title stylePRH 6.14, R5 CIS Disability Data and Accommodation Plans

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Requirements: PRH 6: Section 6.14, R5 (a-f)

a) A DC accurately enters the required data in the disability data collection and accommodation plan icons in CIS after student arrives

Job Corps is required to collect data on the number and types of participants with disabilities served by the program

PRH 6.14, R5 CIS Disability Data and Accommodation Plans

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• The ADA, now known as the Americans with Disabilities Act Amendments Act (ADAAA), was reauthorized in 2009, certain changes to this law affect how we determine who is considered a person with a disability.

• The requirements that directly affect Job Corps are outlined in the Background section of PRH Appendix 605.


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What is the definition of a disability?•A disability is a physical or mental impairment that substantially limits one or more major life activities…


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What is a physical impairment?•A physical impairment is any physiological disorder or condition, cosmetic disfigurement, or anatomical loss affecting one or more of the following body systems:


Neurological Respiratory (Including speech organs)

Special sense organs Reproductive

Cardiovascular Genitourinary

Digestive Skin

Hemic and Lymphatic Immune

Endocrine Circulatory

Musculoskeletal

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What is a mental impairment?•A mental impairment is any mental or psychological disorder, such as intellectual disability, organic brain syndrome, emotional or mental illness, and specific learning disabilities.


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What are major life activities?


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What is are major life activities?•Other major life activities include the operation of a major bodily function, including functions of the immune system; special sense organs and skin;

normal cell growth; and digestive, genitourinary,

bowel, bladder, neurological, brain, respiratory, circulatory,

cardiovascular, endocrine, hemic, lymphatic, musculoskeletal,

and reproductive functions. The operation of a major bodily function includes the operation of an individual organ within a body system.


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Substantial Limitation Determination

When making a determination on whether an individual is substantially limited in performing a major life activity: •The term “substantially limits” should be construed broadly in favor of expansive coverage; “substantially limits” is not meant to be a demanding standard and the determination should not require extensive analysis.•The determination requires an individualized assessment.


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Substantial Limitation Determination•An impairment need not prevent, or severely or significantly limit a major life activity in order to be considered substantially limiting. Nonetheless, every impairment does not constitute a disability.•An impairment is a disability if it substantially limits the ability of an individual to perform a major life activity as compared to most people in the general population.


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Substantial Limitation Determination: Mitigating Measures•When determining whether a person is substantially limited in a major life activity, the beneficial effects of mitigating measures, except ordinary eyeglasses or contact lens, will be ignored. •Mitigating measures are things such as medications, medical equipment or supplies, hearing and mobility support devices, prosthetics, assistive technology, therapy, etc.


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Substantial Limitation Determination and Mitigating Measures•This means that someone who is stable on medication can still be considered an individual with a disability.•If the use of mitigating measure causes any limitations, they will be considered•The use of a mitigating measure cannot be required


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Substantial Limitation Determination: Episodic or Remission•An impairment that is episodic or in remission meets the definition of disability if it would be substantially limiting when it is active •Examples of impairments that may be episodic include epilepsy, hypertension, asthma, diabetes, major depressive disorder, bipolar disorder, and schizophrenia


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Substantial Limitation Determination: Temporary Conditions•The effects of an impairment lasting less than six months can be substantially limiting if sufficiently severe. Typically, impairments that last only a short period of time are not covered.•For example, the individual may have a severe injury such as a broken back, etc.


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Impairments That Are Virtually Always Substantially Limiting•Deafness substantially limits hearing•Blindness substantially limits seeing•An intellectual disability substantially limits brain function•Partially or completely missing limbs or mobility impairments requiring the use of a wheelchair substantially limit musculoskeletal function•Autism substantially limits brain function•Cancer substantially limits normal cell growth


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Impairments That Are Virtually Always Substantially Limiting•Cerebral palsy substantially limits brain function•Diabetes substantially limits endocrine function•Epilepsy substantially limits neurological function•Human Immunodeficiency Virus (HIV) infection substantially limits immune function•Multiple sclerosis substantially limits neurological function


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• Get past the definition of disability ‒ Do not spend a lot of time analyzing whether a student meets the definition of disability; the disability assessment should be done quickly and not demand extensive analysis.

• The disability data collection process is not an exact science, use your best judgment, be consistent, and be prepared to explain your rationale.


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Questions to consider in determining when to count students as having a disability

• Does the student have a physical or mental impairment?

• What major life activity(ies) are impacted?

• Does the impairment substantially limit the student from performing the major life activity(ies) as compared to most people in the general population?

• If the impairment is episodic or in remission; would it be substantially limiting when it is active?


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Questions to consider in determining with to count students as having a disability• Is the impairment one that is considered virtually always

substantially limiting?• If the student is taking medication or using some other

mitigating measure,

− what would his/her condition be like without the benefit of medication or other supports?

− what were the symptoms and the student’s condition prior to the benefit of medication or other supports?

− Is the use of a mitigating measure causing any limitations?


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• How long are the effects of an impairment expected to last? If fewer than 6 months, how severe is the impairment?


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• A lot more individuals will be substantially limited ‒ Remember, the ADAAA reminds us to interpret the definition of disability in favor of broad coverage; when in doubt enter the disability and move on, the focus should be on the interactive process to determine the need for accommodation.


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b) TABE testing accommodations

entered prior to the administration

of the first TABE test


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Section 6.14, R5 (a-f)

c) Only the DCs will have access to the CIS disability data entry screens

d) Generally only DCs will have access to the entry screen; however designee can be appointed and given access to enter accommodation plans


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Section 6.14, R5 (a-f)

e) All center staff providing accommodations will have access to the accommodation plan report in CIS


* Talk with center POC to ensure appropriate access has been provided to staff

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f) Accommodation plans will not contain any medical or diagnostic information − This may include:

• Disclosure of disability

• Reference to types of documentation (IEP, Evaluations)

• Prescription information

• Psychological or Medical evaluations/test results

• Health-related case management notes

• References to treating provider or facility (AA meetings, Therapy appts)

– Should be maintained in student health record


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Resources: PRH 6: Section

6.14, R5 (a-f)• Job Corps Community website –

CIS Wellness

and Accommodation Module Technical Guide– Switched from CIS to CIS 3G

as of 5/20/13• Wellness Accommodation Access

Graphic• Webinar – Provided by JCDC


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Click to edit Master title stylePRH 6.14, R6 Partnerships and Resources

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a) Develop resources and partnerships with outside agencies and programs − Focus on assistance with

identifying or providing accommodations support that promotes students independence and employability

PRH 6.14, R6 Partnerships and Resources

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b) The Business Community Liaison staff and other appropriate staff should be involved in the process


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c) Document efforts by completing the:− Disability Partnership

Tool on the Job Corps Community website or

− Center’s Customized Partnership Tool available from your Regional Disability Coordinator


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Ways to build partnerships:• Develop a relationship with your local vocational

rehabilitation agency• Learn about the services the Job Accommodation

Network (JAN) provides to Job Corps centers• Network (e.g., provide information about Job Corps or

invite to center) with local disability organizations (e.g., centers for independent living, one stops, school systems, colleges/universities)

• Educate local employers about hiring people with disabilities


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Resources:• Webinar – Developing Partnerships• Webinar – Bookshare


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Resources:• Webinar – State Assistive

Technology Programs• Webinar – Job Accommodation

Network (JAN)


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Click to edit Master title stylePRH 6.14, R7 Referral Process

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Section 6.14, R7 (a-b)

a) A written referral/feedback system documenting:− When a student

discloses and may want accommodations or

− When staff suspects a student may have a disability impacting his or her success in Job Corps

PRH 6.14, R7 Referral Process

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Requirements: PRH 6: Section

6.14, R7 (a-b)

b) All forms will be stored in the student’s accommodation file or in the student health record if no accommodation exists

PRH 6.14, R7 Referral Process

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Click to edit Master title stylePRH 6.14, R8 Readily Achievable Barrier Removal

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Requirements: PRH 6: Section 6.14, R8 (a-e)• Centers must consider readily achievable barrier removal

– easily accomplished and inexpensive measures that staff members can do to make the center more accessible to those with disabilities (Exhibit 5-2)

PRH 6.14, R8 Readily Achievable Barrier Removal

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Requirements: PRH 6: Section 6.14,

R8 (a-e)

To accomplish this task centers must:

a) Determine potential improvements to the physical accessibility of the center of the center (e.g. ramps, elevators, adjustable work stations, restrooms, etc.)


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Requirements: PRH 6: Section

6.14, R8 (a-e)To accomplish this task centersmust:

b) Determine potential improvements to the programmatic accessibility of the center (e.g. communication options, large print, disability related displays)


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Requirements: PRH 6: Section 6.14, R8 (a-e)

c) Develop an accessibility plan with priorities and next steps based on the results of the ADA Checklist for Readily Achievable Barrier Removal and Center Accessibility Tool− This plan is NOT intended to be used to determine compliance for

new construction or facility alteration

− Is separate from the center’s facility survey requirement in PRH 5: 5.10


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Requirements: PRH 6: Section 6.14, R8 (a-e)

d) To be reviewed and updated annually by June 30th (Exhibit 5-2)

e) The safety and facilities maintenance staff should play a primary role in completing the plan with support from managers in all areas.


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Resources:• Webinar – Readily Achievable

Barrier Removal


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Click to edit Master title stylePRH 6.14, R9 Staff Training

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Requirements: PRH 6: Section 6.14, R9• Centers will provide disability-related staff training in

accordance with PRH Chapter 5, Exhibit 5-4

PRH 6.14, R9 Staff Training

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Requirements: PRH 6: Section 6.14, R9• Annual disability training for all center staff and • Training for new staff within the 1st 90 days of employment


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Resources: PRH 6: Section 6.14, R9• Job Corps Disability website – Training materials section

for packaged trainings and ideas• Partners – Community resources to provide training• SIMON – New Staff Disability Program Orientation to

train new hires (SIMON is now in Citrix)


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Click to edit Master title styleResources

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• Legal obligation to communicate with individuals with disabilities (WIA)

ResourcesAppendix 606

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• Describes requirements for transmission, storage, and confidentiality of medical, health, and disability-related information

ResourcesAppendix 607

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ResourcesJob Corps Community Website – Disability

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ResourcesSupporting Students with LD

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Resources Job Accommodation Network (JAN)

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Boston Region, Atlanta and Philadelphia Regions – Kristen Philbrook

[email protected]

Dallas Regions – Laura Kuhn

[email protected]

Chicago and San Francisco Regions – Kim Jones

[email protected]

ResourcesRegional Disability Coordinators

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Test Your Knowledge

1. Where can I find sample disability-related student handbook language?

2. How often should all staff training be conducted?

3. The roles and responsibilities of DCs’ should be defined in an _______.

4. If staff suspect students have a disability they should complete a _______ form and forward it to the DC.

5. In the PRH, I can find information regarding the process for an applicant/student with a disability to request reasonable accommodations to participate in the Job Corps program in Appendix ____.

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Questions

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THANK YOU!

Documents

Disability Coordinator Orientation Kimberly Jones, Regional Disability Coordinator