Contract Type: Pre-Employment Transition Services

The contractor and contractor staff that provide services described in this chapter also must comply with Chapters 1–3 of the VRS Standards for Providers manual.

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15.1 Overview Pre-Employment Transition Services

Pre-Employment Transition Services (Pre-ETS) are provided to transitioning individuals who meet the definition of a "student with a disability."

Federal regulations at 34 CFR 361.5(51) define a "student with a disability" as:

" . . . an individual with a disability in a secondary, postsecondary, or other recognized education program who -

(A)(1) Is not younger than the earliest age for the provision of transition services under section 614(d)(1)(A)(i)(VIII) of the Individuals with Disabilities Education Act (20 U.S.C. 1414(d)(1)(A)(i)(VIII)); or

(2) If the State involved elects to use a lower minimum age for receipt of pre-employment transition services under this Act, is not younger than that minimum age; and

(B)(1) Is not older than 21 years of age; or

(2) If the State law for the State provides for a higher maximum age for receipt of services under the Individuals with Disabilities Education Act (20 U.S.C. 1400 et seq.), is not older than that maximum age; and

(C)(1) Is eligible for, and receiving, special education or related services under Part B of the Individuals with Disabilities Education Act (20 U.S.C. 1411 et seq.); or

(2) Is a student who is an individual with a disability, for purposes of section 504."

In Texas, the relevant age range is 14–22 years old.

All services included in a Pre-ETS contract must address one of the key categories defined under the Workforce Innovation and Opportunity Act (WIOA) Pre-Employment Transition Services. As set out in 34 CFR 361.48(a)(2), the five key Pre-ETS required categories are:

"(1) job exploration counseling;

(2) work-based learning experiences, which may include in-school or after school opportunities, or experience outside the traditional school setting (including internships), that is provided in an integrated environment to the maximum extent possible;

(3) counseling on opportunities for enrollment in comprehensive transition or postsecondary educational programs at institutions of higher education;

(4) workplace readiness training to develop social skills and independent living; and

(5) instruction in self-advocacy (including instruction in person-centered planning), which may include peer mentoring (including peer mentoring from individuals with disabilities working in competitive integrated employment).

15.1.1 Examples of Pre-Employment Transition Services

The following are examples of activities that fall into the five required Pre-ETS categories:

  • Job Exploration Counseling—vocational interest inventories, local labor market information–related interests, in-demand occupations, career pathways, vocational evaluations or assessments, Birkman Assessment, and person-centered planning;
  • Work-Based Learning (must be in "real" work setting)—informational interviews to research employers, work site tours, job shadowing, mentoring opportunities in the community, internships, apprenticeships, short-term employment, fellowship, and on-the-job trainings located in the community;
  • Counseling on Postsecondary Opportunities—advising on academic curricula career options, course offerings, types of academic and occupational training needed to succeed in the workplace, and providing resources that may be used to support individual student success in education and training, such as disability support services and financial aid;
  • Workplace Readiness Training (can be in a simulated or "real" work setting)—teaching social skills and independent living skills necessary to prepare for eventual employment, such as communication and interpersonal skills, financial literacy, transportation training, job-seeking skills, understanding employer expectations for punctuality and performance, and other "soft" skills necessary for employment; and
  • Self-advocacy—training on rights and responsibilities; how to request accommodations or services and supports; communicating thoughts, concerns, and needs; peer-mentoring opportunities; and participating in leadership activities offered in educational or community settings. 

It is important to note that no supported employment assessments or benchmarks are included in Pre-ETS.

15.1.2 Pre-ETS Services

Pre-ETS as a service category exists to allow providers some leeway to be creative in combining different Pre-ETS services, such as pairing soft skills for work (job readiness) and work-based learning. If the standards in this chapter are met, the allowable Pre-ETS activities can be any combination of the five required Pre-ETS categories listed above. However, Pre-ETS activities are not required to be a combination of services and can also comprise only one Pre-ETS category. Each provider outlines the services it will provide in the Pre-ETS Proposal . 

To qualify as allowable Pre-ETS services, activities do not necessarily have to be unique, discrete Pre-ETS services. Activities also can be variations on other contracted services as long as the activities fit into the overall definition of required Pre-ETS activities. For example, when a provider provides job readiness training, but the provider's proposal does not meet the standards for Vocational Adjustment Training (VAT) — found in Chapter 13: Work Readiness Services — because the provider is using a different curriculum or providing it for a different number of hours, it may be appropriate for the provider to submit a proposal for a Pre-ETS contract.

The service must be provided as outlined in the DARS1821, Pre-Employment Transition Services (Pre-ETS) Proposal, which was approved when the contract was issued.

15.1.3 No Pre-ETS Proposal Required

Services that qualify as Pre-ETS services do not necessarily require a Pre-ETS proposal. If a provider already holds a contract in good standing for other services that meet the definition of Pre-ETS activities, and will meet all the standards for those services, then no proposal or contract for Pre-ETS is needed. The service will be provided through the existing contract. 

Example 1: A provider wants to create a camp in which the students would receive one week of VAT and one week for work-based learning through Work Experience (WE). If this provider already has a contract for VAT and WE, and all standards for those services are going to be met, the provider can simply market it as a camp that is a combination of those two services, and a Pre-ETS contract will not be necessary.

Example 2: In the same scenario, if the provider wanted to alter any aspect of the services so that the provider is no longer meeting the standards for VAT or WE, the provider submits a Pre-ETS contract proposal in order to continue to provide these services.

For questions about Pre-ETS contracts, staff qualification requirements, proposal requirements, and the like, email the Pre-ETS mailbox at pre-ets@twc.state.tx.us.

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15.2 Staff Qualifications

Before a provider is authorized to provide any services to customers, the Employment Service provider's director must approve the DARS3455, Provider Staff Information form, to be completed by each staff member, such as the trainer and aides, and submit the approved form to the provider's assigned Texas Workforce Commission (TWC) contract manager. The DARS3455 must document qualifications and provide evidence of meeting all qualifications including relevant documentation such as transcripts, diplomas, reference letters, credentials, and licenses. The individual designated as the director must hold the UNT Director Credential. For more information, refer to Chapter 3: Basic Standards, 3.1.5 Director.

All Pre-ETS trainers must meet the following minimum qualifications:

  • High school diploma or General Educational Development (GED) certificate
  • At least one of the following:
    • Two years of experience working with students with disabilities for a school district, as verified with pay statements or a letter of verification from the school district, and a minimum of 30 semester hours of college credit with a minimum of 15 semester hours in special education, specific disabilities, social work, counseling, business, or a related field
    • 60 hours of college credit in special education, specific disabilities, social work, counseling, business, or a related field. Related fields must be approved by the statewide transition specialist.

Exceptions may be granted in cases in which an individual does not meet the educational requirements above if the total of that individual's work experiences clearly demonstrates that he or she is experienced in working with individuals with disabilities, especially transition-age individuals with disabilities. To request a review of an individual's credentials and experience, please email the Pre-ETS mailbox at pre-ets@twc.state.tx.us.

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15.3 Proposal Requirements

The provider must submit a Pre-ETS contract proposal packet for the applicable open enrollment posting.

The Pre-ETS contract proposal packet must include:

The ratio of students to trainers must not be greater than six students to one trainer.

The base rate for Pre-ETS must not be higher than $34.25 per hour for each student attending the program when calculating the total allowable cost.

Food and beverages can be included in the proposals to be purchased for customers only when Pre-ETS activities require and are justified for the participants to stay overnight.

The following goods and services may not be purchased by Vocational Rehabilitation (VR) for customer use (management exceptions are not permitted):

  • Bonding fees
  • Buildings or other structures that require a fixed foundation and/or that are not movable
  • Criminal or civil fines or penalties, including traffic ticket fines
  • Deposits, including, but not limited to, deposits for utilities or sales tax security
  • Fees for registration of inventions, patents, trademarks, or copyright
  • Fees for use of a franchise name
  • Firearms of any kind or components that are part of a firearm
  • Insurance
  • Land
  • Operating capital (for example, for self-employment)
  • State or municipal tax assessments on occupations
  • Vehicles, trailers, boats, or other items that require a certificate of title or registration to be used on public roads, highways, or waterways

Any additional items that are required to support a customer's participation in an approved Pre-ETS program must have prior approval from the VR counselor and will be considered on an item-by-item basis. Items that may be authorized by the VR counselor include uniforms, hygiene products, and required tools and equipment as long as the relationship to the specific employment goal is supported and documented.

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15.4 Contract

The purpose of the contract is to ensure that all parties have a clear understanding of the roles, responsibilities, and resources that are necessary to successfully deliver the services to the customers. Pre-ETS contracts must be authorized and signed by staff in accordance with the applicable signatory authority.

If a contractor is partnering with a third party to provide Pre-ETS, VR may request a contract between all parties.

The TWC Contract Management Unit works with the VR program and administrative staff as well as with other agencies and entities to develop contracts and to provide contract management for all contracts.

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15.5 Process and Procedure

Pre-ETS proposals are accepted during enrollment periods determined by VR and posted in the Electronic State Business Daily website. (See Chapter 2: Obtaining a Contract for Goods and Services and Chapter 3: Basic Standards.)

The VR statewide transition specialist reviews the DARS1821, Pre-ETS Proposal , and all other related materials, and informs the provider whether the proposal has been approved or whether more information is needed.

Once the proposed description of services is approved, and if all other contract requirements are met, a contract will be issued.

Once the contract has been issued, the provider must receive a valid service authorization and the DARS1822 Pre-ETS Pre-Assessment for each customer prior to providing any services.

Services must be provided consistent with the approved DARS1821, Pre-ETS Proposal.

At the completion of training, a DARS1823, Pre-Employment Transition Services (Pre-ETS) Progress Report , must be completed for each student and submitted to the VR counselor with an accurate invoice. Before payment, the VR counselor will complete the DARS1822, Pre-ETS Post-Assessment , to verify that the customer has gained skills, as intended in the DARS1821, Pre-ETS Proposal.

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15.6 Outcomes Required for Payment

For the provider to be paid:

  • providers will only be paid for hours attended by customers. For incomplete hours, time paid will be rounded to the nearest hour that the customer attended on that day. Customers receiving services must attend at least 95 percent of the required program hours per day.
  • the Pre-ETS trainer must document, in the DARS1823, Pre-ETS Progress Report , the outcomes of the Pre-ETS that are purchased.

The DARS1823, Pre-ETS Progress Report , must include evidence that:

  • the training was provided without exceeding the ratio of one staff to six customers;
  • the attendance record indicates 95 percent attendance;
  • the customer's training included all goals from the DARS1821 Pre-ETS Proposal related to the following areas:
  • Career exploration;
  • Work-based learning;
  • Counseling on postsecondary training;
  • Job readiness; and
  • Self-advocacy;
  • all necessary accommodations, compensatory techniques, and special needs were provided to facilitate the customer's engagement in training;
  • various instructional approaches were used to meet the customer's learning style; and
  • all supplies and resources indicated on the Pre-ETS Proposal were provided.

The VR counselor and customer must complete the DARS1822, Pre-ETS Post-Assessment , demonstrating the customer made progress toward achieving the agreed-upon objectives.

An accurate invoice is paid once the VR counselor has verified the customer's attendance and progress, and has completed the DARS1822, Pre-ETS Post-Assessment, to verify the progress documented on the DARS1823, Pre-ETS Progress Report.

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15.7 Pre-Employment Transition Services Fees

The base rate for Pre-ETS must not exceed $34.25 an hour.

The Pre-ETS activity description, including the rate, will be printed on the service authorization.

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